FB 2016: Hybrids – The Latest Changes - McDermott Will & Emery

FB 2016: Hybrids – The Latest Changes

Overview


James Ross wrote this bylined article regarding a revised UK Finance Bill that greatly expands tax provisions covering hybrid mismatch arrangements which involve permanent establishments (PEs). “The effect of these changes is anticipated to be significant in terms of tax take,” Mr. Ross wrote, adding that the changes made “suggest that the government feels it has closed a significant loophole in the previous proposal.”