INTM550040 | Hybrids: introduction: scope of Part 6A, TIOPA 2010

Part 6A targets hybrid mismatches in the following circumstances

Deduction/non-inclusion outcomes involving

• Hybrid financial instruments

• Hybrid transfers

• Hybrid entity payers

• Hybrid entity payees

• Permanent establishments

Double deduction outcomes involving

• Hybrid entities

• Dual resident companies

• Permanent establishments

The legislation also includes rules to deal with arrangements where a mismatch arises entirely outside the UK and is part of the same ‘over-arching arrangement’ as a UK transaction: such arrangements are known as ‘imported’ mismatches. These additional rules are needed to ensure that the legislation cannot be by-passed by routing a mismatch via a third jurisdiction. The imported mismatch rules deal with double deduction or deduction/non-inclusion imported mismatch outcomes involving:

• Hybrid financial instruments

• Hybrid transfers

• Hybrid entity payees

• Hybrid entity payers

• Permanent establishments

• Dual resident companies