The concept of dual inclusion income (DII) under UK hybrid mismatch provisions has undergone substantial changes since its initial introduction to try and ensure its application results in a proportionate and policy aligned outcome. Whilst the changes have been welcome, it remains the case that normal commercial situations could result in an unexpected counteraction. At the same time, HMRC will now have increased information to consider, supplied to it through the UK corporation tax return, which has been updated to include additional disclosures.
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The concept of dual inclusion income (DII) under UK hybrid mismatch provisions has undergone substantial changes since its initial introduction to try and ensure its application results in a proportionate and policy aligned outcome. Whilst the changes have been welcome, it remains the case that normal commercial situations could result in an unexpected counteraction. At the same time, HMRC will now have increased information to consider, supplied to it through the UK corporation tax return, which has been updated to include additional disclosures.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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