The UK government, on April 15, tabled for the Committee of the Whole House amendments to Finance Bill 2021 relating to the corporate tax rules on hybrids and other mismatches.
The government said the changes take into account comments from stakeholders following the publication of Finance Bill 2021. The modifications are being made to ensure that the changes in the bill have the intended effect and do not produce certain unintended consequences like double taxation. The amendments are largely technical and include guidance on the determination of “proportionality.”
The UK rules on hybrids and other mismatches have been in effect since 2017 and implement OECD base erosion and profit shifting (BEPS) action 2 recommendations.
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