Finance Act 2021 has introduced key changes to the UK’s anti-hybrid rules, which will have particular relevance for structures under which a UK borrower raises loan finance from connected and external lenders. The changes relate to the incidence of dual inclusion income and the treatment of hybrid mismatches that are attributable to certain minority and qualifying institutional investors. They also amend the imported mismatch provisions within the anti-hybrid rules, amongst other areas. In general, the changes will improve the application of these rules to UK loan and other investment structures for affected taxpayers, but not in all respects.
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Finance Act 2021 has introduced key changes to the UK’s anti-hybrid rules, which will have particular relevance for structures under which a UK borrower raises loan finance from connected and external lenders. The changes relate to the incidence of dual inclusion income and the treatment of hybrid mismatches that are attributable to certain minority and qualifying institutional investors. They also amend the imported mismatch provisions within the anti-hybrid rules, amongst other areas. In general, the changes will improve the application of these rules to UK loan and other investment structures for affected taxpayers, but not in all respects.
If you are not a subscriber, subscribe now to read this content.
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