Updated hybrids guidance

Published: 18 April 2017


HMRC published in December 2016 draft guidance concerning the application of the hybrids mismatch legislation, which took effect from 1 January 2017. Responses from stakeholders and interested party meetings  have provided HMRC with a range of suggested enhancements and additions that have been consolidated (draft guidance - updated version). A summary of the main themes identified, and a list of respondents, can be found here. HMRC has adopted some suggestions and corrected some inconsistencies and is continuing to engage with the respondents to provide additional material before the guidance is finalised. HMRC intends to incorporate the guidance into the International Manual over the next six months, once the additional material has been provided and worked through. HMRC will continue to monitor use of the guidance and to add to it where additional material may be helpful. AIMA is proposing to submit comments to HMRC shortly. For further information, please contact Paul Hale and Enrique Clemente.