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HMRC letters on CIR, hybrid mismatches and loss reform

HMRC letters on CIR, hybrid mismatches and loss reform

Some businesses are receiving letters from HMRC informing them of recent changes that may impact their tax position.

Chris Davidson

Tax Director

KPMG in the UK


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We have become aware that a number of taxpayers have received letters from HMRC highlighting three measures that have recently become effective and that may impact on the business’s tax position. These measures are Corporate Interest Restriction (CIR), hybrid mismatches, and loss reform. Although we believe that these letters are targeted at groups of companies containing a general fact pattern, there is nothing to suggest that HMRC have a particular concern with that specific business. However, the letter does indicate that HMRC believe that one or all of the new regimes should be applying to that business. Consequentially, there is an increased risk that those groups receiving the letter may be further contacted by HMRC with more specific questions.

We would therefore recommend that all businesses who receive these letters review their CIR, hybrid mismatch, and loss reform positions, to ensure that they have applied the new rules appropriately and to allow them to respond to any future HMRC questions that may be forthcoming.

If you have any questions about a letter you may have received, or on CIR, hybrid mismatches and loss reform in general, then please get in touch with your usual KPMG contact.

For further information please contact:

Chris Davidson

Kevin Elliott

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