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Hybrids: changes to HMRC’s revised draft guidance

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On 1 December 2017, the new Finance (No. 2) Bill was published. The Bill contained a number of amendments to the hybrid and other mismatches legislation, most of which are retrospective back to 1 January 2017, with the remainder applying from 1 January 2018. In addition, on 29 November 2017, HMRC published a draft of its updated guidance on the legislation, which assists in understanding how it expects the rules to be applied in practice. These amendments include: extending the recognition of dual inclusion income in some chapters; deeming a mismatch to arise by reason of a company operating through a permanent establishment in a specified case; further clarifications on when unilateral deductions are outside scope; recognising capital taxes in specific circumstances; and putting beyond doubt some stances HMRC took in prior drafts of its guidance by legislating for them. 

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