Revenue eBrief No. 068/21
29 March 2021
Tax and Duty Manual Part 35C-00-01, which provides guidance on the anti-hybrid rules, has been updated to include:
- amendments made by Finance Act 2020 to how the anti-hybrid rules apply to worldwide systems of taxation,
- key terms used in the anti-hybrid rules such as "payee", "reasonable to consider" and "associated enterprise", and
- the "imported mismatch" rule.