2 Part Course  | 
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Hybrid Mismatch Rules

2 Part Course  |  This course covers the principles of hybrid rules as outlined in BEPS recommendation 2

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A one-day course presented over two-half days in a virtual class

In-house pricing available – often more cost-effective for teams of 10+
pdf Download:   Course Outline

Part One

  • Hybrid payers – This looks at dual resident companies as well as the permanent establishment of foreign branches
  • Hybrid payees – recipients of payments which may have inconsistent tax treatment across borders
  • Hybrid instruments – Identifying instruments which have different tax treatments in different jurisdictions
  • 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 laws
  • Key terms and definitions used in the law
    • Tax, payment, quasi-payment, payer, payee, ordinary income
  • Hybrid entities – definition and examples
  • Control groups and related persons and their importance in the conditions for the hybrid legislation to apply
  • Financial instruments (D/NI) mismatches – conditions, counteractions and examples
  • Hybrid transfers (D/NI mismatch) – conditions, counteractions and examples

Examples Used

  • Generic D/NI mismatch
  • Generic DD mismatch
  • Hybrid financial instruments (D/NI mismatches)
  • Generic hybrid transfers mismatch
  • Zero-coupon convertible loan note
  • Undertaxed income

 

Part Two

  • Third-party transactions – how the legislation deals with transactions routed through different jurisdictions and the effect of the imported mismatch rules
  • Interaction with other tax legislation – There are other elements, such as the transfer pricing and unallowable purpose rule,s which would seem to overlap with the hybrid rules:
    • How the interactions work
  • Hybrid payer (D/NI) mismatch – conditions, counteractions and examples
  • Hybrid payee (D/NI) mismatch – conditions, counteractions and examples
  • UK permanent establishments of multinational entities (D/NI mismatches) –
  • conditions, counteractions and examples
  • Hybrid entity DD mismatches – conditions, counteractions and examples
  • Dual inclusion income in DD mismatched

Examples Used

  • Imported mismatch – hybrid financial instruments issued and invested in outside of the UK
  • Transfers by a UK branch of a multinational parent
  • Real case study scenario to analyse and conclude on

A distinguished UK Chartered Accountant and Chartered Tax Advisor delivers Redcliffe's Hybrid Mismatch Rules course.

With over 30 years of experience, he has held senior roles including Director of Finance and Taxation Programmes at BPP Professional Education. Leading many IFRS, US GAAP, UK Tax, and VAT courses for organisations around the globe, his expertise is especially prominent in providing bespoke IFRS and US GAAP training for multinational corporations in sectors such as financial services, transport, and energy, while also delivering UK tax and VAT updates to leading law and accounting firms.

As a passionate educator, his dynamic training sessions are not only informative but also engaging, encouraging interaction and real-world discussion among participants. He serves as a consultant to businesses and accounting firms, offering insights on tax, VAT, accounting policy reviews, and transaction treatments.

He earned the prestigious John Wood Medal in the November 1995 CIOT exam for the top performance in business taxation.

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.

  • The trainer was incredibly knowledgeable and came across really well. What I particularly liked is that he didn't just talk at you, but opened up a dialogue for a productive discussion amongst attendees. This course has helped me understand some more of the nuances of the complex anti-hybrid legislation and how we can utilise this to make sure our clients with an international presence are fully compliant.
  • The tutor was engaging and very knowledgeable on this topic and across corporation tax in general, making helpful links between topics. Many detailed examples are covered.
  • The course was very useful, giving a good mix of technical content and worked examples.
Number of places:
Part 1

£ 695.00

Number of places:
Part 2

£ 695.00

Discounts available:

  • 2 places at 30% less
  • 3 places at 40% less
  • 4+ places at 50% less
  • Select the number of course places and dates to automatically calculate the discount
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