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).