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Finance Act 2021 has introduced key changes to the UK's anti-hybrid rules, which will have particular relevance for structures under which a UK borrower raises loan finance from connected and external lenders. The changes relate to the incidence of dual inclusion income and the treatment of hybrid mismatches that are attributable to certain minority and qualifying institutional investors. They also amend the imported mismatch provisions within the anti-hybrid rules, amongst other areas. In general, the changes will improve the application of these rules to UK loan and other investment structures for affected taxpayers, but not in all respects.
Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK's anti-hybrid rules.
Finance Act 2021 has recently made important changes to the UK's anti-hybrid rules in TIOPA 2010 Part 6A. The changes not only apply to structures under which a UK company borrows money from connected and external lenders (referred to below as...

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