Chapter 5

Hybrid entities

Summary

This sets out the anti-hybrid rules relating to hybrid entities.

835AK Application of chapter

Summary

This section sets out the entities and transaction(s) to which this chapter applies.

Details

(1) This chapter shall apply to a transaction that gives rise to a mismatch outcome between—

1. entities that are associated enterprises,
2. the head office of an entity and a permanent establishment of that entity, or
3. two or more permanent establishments of an entity.

(2) Section 835AL (Payment to hybrid entity deduction without inclusion mismatch outcome) applies to a company which is within the charge to corporation tax.

(3) Section 835AM (Payment by hybrid entity deduction without inclusion mismatch outcome) applies to a company which is within the charge to foreign tax or corporation tax.

Relevant Date: Finance Act 2019