Hybrid Mismatch Rules

This Hybrid Mismatch Rules course is led by a seasoned tax professional who is the director of a consultancy firm specialising in taxation, share schemes, and reward strategies. With a wealth of experience advising both small companies and FTSE-listed corporations, he has developed a specialised share scheme service tailored for SMEs, while also guiding large corporates on effective communication strategies. His passion lies in employment taxation and transfer pricing, areas with conceptual complexities.

Having previously led the Share Schemes team at Henderson during his 9-year tenure, he completed a CIPD Level 7 Master's qualification, solidifying his expertise in reward and employee compensation strategies. Before that, while working for the Australian Mutual Provident (AMP), he played a pioneering role in establishing one of the first Share Incentive Plans (SIPs) for large companies in 2001. His work was so innovative that HMRC reached out to learn how more companies could be encouraged to adopt SIPs.

His early career saw him in senior roles at three of the “Big Four” accountancy firms, including Deloitte, where he rose to Senior Manager. His work spanned profit-related pay, expatriate tax, tax investigations, reward management, US taxation, and corporate tax, giving him a broad foundation in complex tax matters.

Outside of his professional pursuits, he enjoys cricket, history, skiing, tennis, and gardening, and frequently lectures on historical topics to keep his presentation skills sharp and engaging.

By the end of this course, participants will be able to:

• Understand the origins of the hybrid mismatch rules and navigate the various chapters of the UK hybrid legislation.
• Define hybrid mismatches and identify situations where they may arise.
• Differentiate between the types of mismatches. You will be able to identify the correct conditions applied to assess potential counteraction.
• Recognise situations where no mismatch occurs.
• Calculate the necessary adjustments resulting from a hybrid mismatch.
• Analyse updates introduced by the Finance Act 2021 and understand how these changes impact the original hybrid legislation

• We use real-world applications and a variety of examples that break down complex rules into digestible concepts.
• This course leader is an experienced, independent training professional.
• The course provides an objective view, free from organisational bias, allowing participants to form their own interpretations.
• Active participation is encouraged during this presentation. Attendees should ask questions and engage in discussions to clarify their understanding.
• The content is continuously updated to reflect the latest developments in hybrid mismatch rules, ensuring relevance in today’s regulatory environment.

Our hybrid mismatch rules course is a ‘must know’ for:

• Tax professionals involved in the preparation or review of UK hybrid corporation tax computations of multinational companies. Especially but not exclusively where a UK company has a US parent or a US major corporate hybrid investor, or where the UK entity is a branch of a multinational company or group.

The course is a ‘nice to know’ for:

• CFOs, FDs and FCs to understand the possible tax adjustments that may be necessary for a UK subsidiary of a foreign parent (especially a US parent) or a UK branch of a multinational group.

This two-part Hybrid Mismatch Rules course will deepen your understanding of when UK companies and branches may encounter disallowances under the hybrid mismatch anti- hybrid rules. The course methodically guides participants through identifying different types of mismatches, understanding the conditions that trigger counteraction, and evaluating how to resolve mismatches.

Through hands-on examples and case studies, attendees will learn how to classify potential mismatches—a critical skill since each mismatch type has unique counteraction criteria. As a capstone exercise, delegates will analyse a real-world scenario involving hybrid mismatch advice provided by the trainer, testing their practical knowledge and reinforcing the learning outcomes.