Hybrid Mismatch Rules

Our Hybrid Mismatch Rules trainer is a distinguished UK Chartered Accountant and Chartered Tax Advisor, earning the prestigious John Wood Medal in the November 1995 CIOT exam for the top performance in business taxation. With over 30 years of experience, he has held senior roles, including Director of Finance and Taxation Programmes at BPP Professional Education, where he led numerous 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, he ensures that his dynamic training sessions are not only informative but also engaging, encouraging interaction and real-world discussion among participants. In addition to delivering Redcliffe’s hybrid mismatch rules course, he serves as a consultant to businesses and accounting firms, offering insights on tax, VAT, accounting policy reviews, and transaction treatments.

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, ensuring that the correct conditions are applied to assess potential counteraction.
• Recognise situations where no mismatch occurs.
• Calculate 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

• The course emphasizes real-world applications, integrating a variety of examples that break down complex rules into digestible concepts.
• Led by an experienced, independent training professional, the course provides an objective view, free from organizational bias, allowing participants to form their own interpretations.
• This course is designed to promote active participation. Attendees are encouraged to 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 is crafted to help 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 mismatches are resolved.

Through hands-on examples and case studies, attendees will learn how to correctly 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.