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Hybrid Mismatch Rules

2 Part Course  |  Identify when the rules could apply to a corporation tax computation and what adjustments may be needed

Hybrid Mismatch Rules Training Course

A one-day course presented in two half-day live webinars

Video Overview

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and meet your trainer.

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This course is a ‘must know’ for;
  • tax professionals involved in the preparation or review of UK corporation tax computations of multi-national companies, especially but not exclusively where a UK company has a US parent or a US major corporate investor, or where the UK entity is a branch of a multi-national 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 for a UK branch of a multi-national group.

  • The course is highly practical and will include multiple examples to assist with understanding the rules
  • It is presented by an independent training professional and can be a completely independent look at the issues raised
  • The course will encourage participation and allow for all questions and clarifications to be considered
  • The course will always be completely current and relevant

  • Understand the source of the hybrid mismatch rules and different chapters of the UK legislation
  • Understand what a hybrid mismatch is and when it can arise
  • Distinguish the different types of mismatch to ensure the correct conditions are used to identify if there is a potential mismatch that may need counteracting
  • Understand when a mismatch does not arise
  • Calculate adjustments arising out of a mismatch
  • Understand the changes in Finance Act 2021 and how they relate to the original legislation

Part One

  • Part 6A TIOPA 2010 – a summary of each chapter
  • Introductory examples of potential mismatches
  • Deduction/non-inclusion (D/NI) mismatches
  • Double deduction (DD) mismatches
  • Primary and secondary responses to mismatches – how the mismatch is counteracted
  • Interaction with other tax law
  • Key terms and definitions used in the law
    • Tax, payment, quasi-payment, payer, payee, ordinary income
  • Hybrid entities – definition and examples
  • Hybrid entities – effect of US ‘check the box’ elections
  • Relevant investment funds and exemption from the rules
  • Control groups and related persons and their importance in the conditions for the legislation to apply
  • Financial instruments (D/NI) mismatches – conditions, counteractions and examples
  • Hybrid transfers (D/NI mismatch) – conditions, counteractions and examples
  • Hybrid transfers – financial trader exclusion

Examples used:

  • Generic D/NI mismatch
  • Generic DD mismatch
  • Hybrid financial instrument (D/NI mismatches)
  • Generic hybrid entities mismatch
  • Generic hybrid transfers mismatch
  • Zero-coupon convertible loan note
  • Interest-free loans with special tax rules
  • Undertaxed income
  • Exchange losses on cross-border debt instruments
  • Interest-bearing intra-group cross-border loan
  • Loan release Cross-border hybrid instrument issued by tax-exempt parent charity
  • Repos
  • Foreign currency losses on repos

Part Two

  • Hybrid payer (D/NI) mismatch – conditions, counteractions and examples
  • Hybrid payee (D/NI) mismatch – conditions, counteractions and examples
  • Dual inclusion income in D/NI mismatches – definition and examples
  • UK permanent establishments of multinational entities (D/NI mismatches) –
  • conditions, counteractions and examples
  • Multinational payee (D/NI) mismatches – conditions, counteractions and
  • Examples
  • Hybrid entity DD mismatches – conditions, counteractions and examples
  • Dual territory cases (DD mismatches) – conditions, counteractions and
  • examples
  • Dual inclusion income in DD mismatched
  • Imported mismatches – where a mismatch occurs outside the UK but must be adjusted by a UK company

Examples used:

  • A loan from US parent to UK subsidiary – effect of ‘check the box’ elections
  • Dual inclusion income in D/NI mismatches x 3
  • Third-party loan to a UK subsidiary of a US company – effect of ‘check the box’
  • elections
  • Imported mismatch – hybrid financial instrument issued and invested in outside
  • UK x 2
  • Transfers by a UK branch of a multinational parent
  • Dual territory DD mismatch – third party loan to the foreign parent, partly used
  • by UK branch x 2
  • Real case study scenario to analyse and conclude on

The trainer is a UK Chartered Accountant and Chartered Tax Advisor winning the John Wood Medal in the November 1995 CIOT sitting for the best paper on business taxation.

He was previously Director of Finance and Taxation Programmes at BPP Professional Education and has delivered IFRS, US GAAP, UK Tax and VAT to a multitude of organisations world-wide since 1992.

He has particular experience in delivering bespoke IFRS and US GAAP training programmes to multi-nationals in the financial services, transport and energy sectors as well as delivering UK tax and VAT update programmes to accounting and law firms.

The trainer is passionate about training and his enthusiasm ensures that the participants enjoy the learning experience whilst gaining knowledge through their engagement in the sessions and through encouraging them to ask questions and discuss practical issues they may have.

He also provides consultancy services to companies and accounting firms, including provision of tax and VAT advice, reviewing accounting policy manuals and advising on accounting treatments of various transactions.

This two-part webinar is designed to help attendees understand when UK companies and branches might face a disallowance under the hybrid mismatch rules.

It will guide delegates through the process of identifying the different types of mismatch that can arise and the conditions that need to be met for counteraction to be considered, as well as how the mismatch is actually counteracted, if at all.

Delegates will learn through multiple examples how to identify potential mismatches and exactly what type of mismatch it is, which is vital as the conditions for potential counteraction are different in each case.

They will have an opportunity to assess their knowledge by analysing a real-life scenario where advice was sought from the trainer.

  • Good examples of situations potentially impacted by the hybrid rules. Updated slides including refs to the legislation were appreciated.
  • The instructor was a brilliant presenter and very clearly explained the concepts and application of the rules. It has provided some much needed clarity to real life scenarios we are trying to advise our client on.
  • The speaker was absolutely brilliant, very clear and concise and took time to make sure questions were answered and things were explained clearly.
Number of places:
Part 1
Number of places:
Part 2

£895.00

Per participant per part
Discounts available for multiple place booking find out more
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