HMRC has published practical examples of how the new hybrid mismatch rules will be applied. Although the examples don’t make this difficult legislation any easier, they do at least link the UK rules together with the mischief they are supposed to prevent, as identified in the final BEPS report. There is a clean bill of health for the banks in the first annual report on the code of practice on taxation for banks. Regulations setting out the detailed conditions for the new withholding tax exemption for qualifying private placements come into effect. Amendments are made to the taxation of regulatory capital securities regulations.
