Pillar Two, CFCs and Hybrid Mismatches – Managing Overlapping UK Tax Rules

• Establishing scope: why the three regimes can apply to different populations of companies and transactions.
• Pillar Two: an overview of the UK top-up taxes, effective tax rate calculations and relevant safe harbours.
• CFCs: identifying potentially relevant overseas companies, charging gateways and exemptions.
• Hybrid mismatches: recognising deduction/non-inclusion, double deduction and imported mismatch risks.
• Applying the regimes together: a case study involving an overseas subsidiary and intragroup funding, highlighting tax adjustments, information dependencies and potential overlaps.
• Budget 2026: the areas being considered for CFC and anti-hybrid simplification, and the obligations groups must continue to assess while that work develops.

Redcliffe's course trainer is the CEO and Tax Advisor at a tax consultancy / advisory firm. He advises internationally active businesses and individuals on UK and cross-border tax, with a particular focus on permanent establishment risk, corporate residence/POEM, treaty positions and documentation, and cross-border structuring (including withholding tax considerations and transfer pricing).

The trainer lectures in International Taxation (CIOT/ADIT context) and has held senior tax leadership and advisory roles, including Head of Tax for the Diacron Group and consulting/advisory work with other International Tax firms (including Bain & Company). He has worked across multiple jurisdictions, including the UK, Italy, the US and Costa Rica, and brings a practitioner-led, case-driven approach that is grounded in real client scenarios.

Delegates will be able to map the relevant regimes across a group structure, identify the principal interaction risks and prepare a coordinated information request and compliance plan.

Designed for corporate and international tax advisers and in-house tax professionals with a working knowledge of multinational group taxation.

An applied session examining how Pillar Two, the UK controlled foreign company rules and the hybrid mismatch rules can affect the same group. The emphasis will be on identifying which regimes apply, understanding their different purposes and managing the information needed to assess their interaction.