On 6 December 2010, HMRC made several potentially landscape-changing announcements targeted at corporate tax planning. Scheduled to take effect from Royal Assent expected in July 2011, draft legislation aimed at countering planning involving asymmetric treatment of loans and derivatives between group companies (‘Group Mismatches’) was released. Measures to close loopholes around group convertibles and financial asset derecognition were introduced with immediate effect. The ‘cat and mouse’ cycle of financial product disclosures followed by specific anti-avoidance measures is likely drawing to a close.
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