SolvedINTM550090 | Hybrids: introduction: summary of Part 6A
From HM Revenue & Customs · International Manual
| Type | Mismatch Involving | Primary Response | Defensive Rule | Scope |
|---|---|---|---|---|
| D/NI | Chapter 3: Financial Instruments | Deny payer deduction | Include as ordinary income | Related parties and structured arrangements |
| D/NI | Chapter 4: Hybrid Transfers | Deny payer deduction | Include as ordinary income | Related parties and structured arrangements |
| D/NI | Chapter 5: Hybrid Payer | Deny payer deduction | Include as ordinary income | Control group and structured arrangements |
| D/NI | Chapter 6: Permanent Establishments | Deny deduction to UK PE | - | UK permanent establishments |
| D/NI | Chapter 7: Hybrid Payee | Deny payer deduction | Include as ordinary income of investor, then LLP | Control group and structured arrangements |
| D/NI | Chapter 8: Multinational Payee | Deny payer deduction | - | Control group and structured arrangements |
| DD | Chapter 9: Hybrid Entity | Deny investor deduction | Deny payer deduction | Related parties and structured arrangements |
| DD | Chapter 10: Dual Territory | Dual resident company: deny deduction / Multinational company: deny parent jurisdiction deduction | Multinational company: deny deduction to UK PE | Dual resident and multinational companies |
| D/NI / DD | Chapter 11: Imported Mismatches | Deny payer deduction | - | Control group and structured arrangements |