On March 19, 2020, the UK tax authority issued for public comments a consultation document on the impact of the double deduction rules and the acting together rules within the hybrid and other mismatches regime at Part 6A of the Taxation (International and Other Provisions) Act, 2010.
Stakeholders have raised concerns that the rules in relation to double deductions are disproportionate, the acting together rules are too widely drawn, and that in some cases taxpayers are unable to obtain the necessary third party information required to fully comply with the legislative requirements.
The tax authority is inviting comments on both the technical application of the rules and impact of the policy as enacted. The move is aimed at ensuring that the rules operate proportionately, as intended.
The consultation closes on May 29, 2020.
See Consultation Document