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Contents

Official guidance
International Manual

INTM550500 · Hybrids: definition of key terms

  • INTM550510 · Arrangements within the scope of Part 6A
  • INTM550520 · Meaning of tax
  • INTM550530 · Equivalent provision under the law of a territory outside the United Kingdom
  • INTM550540 · Payment and quasi-payment, securitisation companies
  • INTM550550 · Payer and payee
  • INTM550560 · Ordinary income
  • INTM550570 · Ordinary income of controlled foreign companies
  • INTM550580 · Hybrid entities, residence, investors and investor jurisdiction
  • INTM550590 · Permanent establishment
  • INTM550600 · Financial instruments and relevant investment funds
  • INTM550610 · Control groups and related persons
  • INTM550620 · 50% investment and 25% investment
  • INTM550630 · Partnership and partnership members
  • INTM550640 · Reasonable to suppose
  • INTM550650 · Structured arrangements
  • INTM550660 · Summary
  1. Hybrids: definition of key terms: contents
  2. Hybrids: definition of key terms: arrangements within the scope of Part 6A

INTM550510 | Hybrids: definition of key terms: arrangements within the scope of Part 6A

From HM Revenue & Customs · International Manual

Part 6A of TIOPA 10 applies to mismatches involving

  • financial instruments as defined in s259N

  • hybrid entities as defined in s259BE

  • UK permanent establishments of multi-national companies as defined in s259BF

  • multi-national companies as defined in s259HA(4)

  • dual resident companies as defined in s259JA(3)

  • hybrid payees as defined in s259GA(3)

  • hybrid payers as defined in s259EA(3)

  • hybrid transfer arrangements as defined in s259DB

  • imported mismatch arrangements as defined in s259KA

Other key expressions for Part 6A of TIOPA 10 are defined in chapters 1, 2 and 14, and additional definitions are included within the chapters to which they apply.

An index of defined expressions is set out at Part 4A of Schedule 11, TIOPA 10 (as amended by paragraph 17 of Schedule 10, FA 16).

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