On July 8, 2020, the Irish Revenue issued guidance on the operation of the country’s anti-hybrid rules, which were introduced into Part 35C TCA 1997 by Finance Act 2019.
The guidance sets out information relating to what is meant by a mismatch outcome, being a double deduction mismatch outcome or a deduction without inclusion mismatch outcome, and the specific situations that give rise to a hybrid mismatch outcome.
Guidance is also provided on the meaning of the term “corresponding amount” and how to test whether a corresponding amount has been included for the purposes of the anti-hybrid rules in various scenarios.
Finally, the guidance provides information on how the anti-hybrid rules interact with Ireland’s worldwide system of taxation and how the rules interact with an effective worldwide system of taxation such as the US check-the-box system of taxation.
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