INTM555100 | Hybrids: hybrid payee (Chapter 7): counteraction: contents

Counteraction to address the hybrid payee deduction/non-inclusion mismatch is considered first in respect of the payer (the primary counteraction).

The second counteraction, against investors in the hybrid payee(s), applies if the payer is not within the charge to UK corporation tax.

The third counteraction, against an LLP that is a hybrid payee, applies if the primary counteraction and the secondary counteraction do not apply to address the mismatch.

Details of each of the counteractions are provided in the following pages.