A knotty problem

Tom Blessington reviews the issues surrounding anti-hybrid legislation and how commercial arrangements may fall within them even without a tax avoidance motive

Back in July 2017, Tax Adviser published an article on the UK’s forthcoming anti-hybrid rules. Now the rules have been in force for a few years, it is worth revisiting what a hybrid is and how commercially unremarkable arrangements, without a tax avoidance motivation, may fall within the UK’s anti-hybrid legislation. These rules are legislated within Part 6A of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010).