Hybrid arrangement meaning

Banking & Finance—June 2025 case round-up Waller-Edwards v One Savings Bank Plc [2025] UKSC 22 Undue influence—mixed non-commercial transactions—de minimis threshold—Etridge guidance In this appeal, the Supreme Court allowed the challenge unanimously, deciding that a creditor is placed on inquiry—that one party’s assent to the deal may have been procured through undue influence—whenever a non-commercial hybrid arrangement, on the face of it, features a more than de minimis (ie trivial) borrowing component that extinguishes the liabilities of only one co-borrower and so may not be to the other’s financial advantage. Joanne Wicks KC, barrister at Wilberforce Chambers, and Tricia Hemans, barrister at Falcon Chambers, consider the ruling’s implications in News Analysis: Supreme Court holds banks must follow the Etridge protocol where non-commercial hybrid transactions include a more than de minimis surety element (Waller-Edwards v One Savings Bank Plc). This reiterates the Etridge principle in the context of such arrangements, for banks and lenders...

Brexit highlights In this issue: Brexit SI Constitutional and administrative law Judicial review Public procurement Subsidy control and State aid Information law State security and intelligence Other public law news Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information UK-EU relations—Government responds to Business and Trade Committee report The government has issued its reply to the House of Commons Business and Trade Committee’s Sixth Special Report of Session 2024–25, ‘How to strengthen UK-EU relations: Policy Priorities for the Summit’. It sets out outcomes from the May 2025 UK-EU Summit, including a new UK-EU Security and Defence Partnership to deepen defence industrial co-operation and respond to hybrid threats and weaknesses in critical infrastructure. The response also confirms agreement on Sanitary and Phytosanitary measures, a 12-year fisheries arrangement, and stronger law enforcement co-operation. Further priorities include joint action to address non-market economies and economic crime,...

When the statutory entitlement to seek remote and flexible ways of working was introduced, employees largely viewed it as a sign of shifting post-pandemic workplace norms. Yet recent WRC decisions have explored the boundaries of the remedies available to employees under this legislation. Together with moves by some public and private sector employers to increase office attendance, this has triggered a wider debate on the outlook for hybrid work in Ireland... Background Under the Work Life Balance and Miscellaneous Provisions Act 2023 (the Act), all employees may request a remote working arrangement (RWA); if approved, it can commence once six months’ service with the employer has been completed. The Act also enables certain categories of employees to request flexible working for caring duties. Following the Act, the Code of Practice on the Right to Request Flexible and Remote Working (the Code of Practice) was issued in March 2024. Our article on the Code of Practice (available here) outlined guidance to help employers and employees comply with the Act...

The UK’s rules on hybrid and other mismatches Since 1 January 2017, the UK’s hybrid and other mismatch rules (described in this Practice Note as the hybrid rules) have been in force, designed to neutralise tax mismatches arising from how a hybrid instrument or hybrid entity is treated for tax. Although the hybrid rules typically apply to cross-border dealings involving two or more jurisdictions, they can also apply to transactions that are entirely UK domestic. They specifically address: deduction/non-inclusion mismatches (D/NI mismatches), i.e. where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but is not included in the taxable income of a payee or a related party investor; and double deduction cases (DD cases), i.e. where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction. For more detail on the hybrid rules, see Practice Note: Hybrid mismatches—introduction to the rules. For an overview in table form of...

This Practice Note sets out the principal steps for properly bringing to an end a defined contribution (DC) occupational pension scheme—also described as a money purchase occupational pension arrangement or a trust-based defined contribution plan. Throughout this Practice Note, this type of arrangement is termed a ‘DC scheme’. The guidance applies across a range of DC schemes, including trusts that sit outside the authorised master trust framework and small self-administered pension schemes (SSASs), although the latter may, in certain cases, be excluded from particular statutory obligations or requirements. This Practice Note does not cover the winding-up of any: an ‘authorised master trust’ under the Pension Schemes Act 2017 (PSA 2017)—for further detailed information, please see Practice Note: The authorisation and supervisory regime for master trusts, contract-based DC arrangements (eg group personal pension arrangements)—for further details and guidance, see Practice Note: Winding up of personal pension schemes Statute makes distinct and specific provision for hybrid schemes (combining defined benefit (DB) and DC...

This Practice Note provides a checklist in the form of a high-level summary of the key anti-avoidance rules that may apply to restrict the tax deductibility of loan interest for a corporate borrower within the charge to UK corporation tax. They include: the loan relationships regime-wide anti-avoidance rule (RAAR) the unallowable purpose rule the rules recharacterising interest as a distribution the corporate interest restriction the transfer pricing rules the hybrid and other mismatches rules non-market loans the general anti-abuse rule For these purposes, assume the borrower and lender are unrelated and deal strictly on a commercial arm’s length basis in relation to a bilateral or syndicated loan arrangement...

Firm name [ Insert firm name ] Role holder’s name [ Insert name ] Reports to [ Senior partner OR Board OR Management committee ] Role category (full-time/part-time/contractor) [ Insert ] If contracting, contract duration [ Insert ] Primary location [ Insert the main location for this role—if the role holder is required to spend time regularly in more than one place, eg each regional office, make sure this is clearly stated ] Working arrangement (remote/hybrid/office-based) [ Insert type of work model ] Role start date [ Insert date ] Probation period length [ Insert ] Probation review end date [ Insert date ] Role summary The managing partner is the most senior manager on the [ Board OR Management committee ], accountable for sound governance, crafting the firm’s strategic direction and vision, and executing the agreed strategy...

Key information Firm name [ Enter firm name ] Role holder’s name [ Enter name ] Reporting line [ Head of Human Resources (HR), HR manager, or Head of Professional Standards and Training ] Role type [ Specify, eg full-time/part-time/contractor ] [ If a contractor post, include contract length ] Main location [ State the primary base for this role—if the role holder must routinely spend time in multiple locations, eg each regional office, ensure this is clearly stated ] Working arrangement [ Remote/hybrid/office-based? ]...

A: Employee details Full name [ Enter employee’s name ] Commencement date [ Enter ] Role title [ Enter ] Reporting manager [ Enter ] Department [ Enter ] Main workplace [ Enter location, e.g. the principal place the employee will be based ] Working arrangement? Remote/Hybrid/Office-based? ...