More than two and a half years since the anti-hybrid rules in Part 6A TIOPA 2010 were introduced, we are still seeing financial services groups continue to be challenged by a lack of certainty around their application. In part, this is because the rules are still relatively new (with HMRC’s view of how to apply the legislation in practice still emerging) and they have continued to evolve since their original introduction. However, this of course is not itself a full explanation for why the rules remain so difficult to navigate, as these same challenges would arise in respect of any new legislation. What is unique about the anti-hybrid rules is that they sit within a perfect storm of considerable complexity, wide-reaching breadth of application and interaction with overseas tax rules that are in a state of flux.
In this article, we explore a number of areas of the rules that we have seen financial services organisations grapple with recently, including issues that have arisen due to changes in corporate structure or business models, whether linked to Brexit, US tax reform or other factors.
Please refer to the link below for the full article.
