KPMG’s Rob Norris and Mark Eaton consider HMRC’s updated guidance on the UK hybrid and other mismatches rules.
The updated guidance reflects various legislative changes made to the hybrid mismatch rules since inception (with a useful summary of these now being included at INTM550095). It also provides helpful clarification of HMRC’s position on a number of points of interpretation (although there are still several residual areas of interpretation where uncertainty remains).
Some key points of interest emerging from the revised guidance are as follows:
The updated guidance is available here: http://www.hmrc.gov.uk/gds/INTM/images/INTM850000_hybrids.pdf. Note that the HMRC mailbox has now been changed to email@example.com and the address for hybrid claims etc. has now been updated to a Newcastle address.
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