Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Rules definition

What does Rules mean? Rules describes the written provisions that govern how a pension scheme operates—especially occupational pension schemes—usually contained in, or annexed to, the trust deed (trust deed and rules). Legislation refers to these as scheme rules (for example, Pensions Act 1995 and Pensions Act 2004 in the UK, and the Pensions Act 1990 in Ireland). Scheme rules set out eligibility, benefit structure (defined benefit or defined contribution), contributions, service and accrual, retirement options and ages, revaluation/indexation, ill‑health and death benefits, transfers in and out, leaver provisions, forfeiture, augmentation, priority on winding‑up, discretions and decision‑making, and the scheme’s amendment and termination powers. They also...

UK corporation tax: hybrid and other mismatch rules (TIOPA 2010 Part 6A)—overview, operation, legislative updates, clearances, commencement, interaction with other rules, dual inclusion income and TAAR

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Practice notes

Hybrid Rules

This Practice Note sets out the UK provisions (referred to in this Practice Note as the hybrid rules) that, for corporation tax purposes, neutralise hybrid and other mismatch Outcomes. Such mismatches exploit differences in the tax treatment of an entity or instrument under the laws of two or more jurisdictions to produce double non-taxation, including extended deferral.

Although the hybrid rules are said to be grounded in the OECD/G20 Final Report on BEPS Action 2: Neutralising the Effects of Hybrid Mismatch Arrangements (5 October 2015) and the OECD’s Report on BEPS Action 2: Neutralising the Effects of Branch Mismatch Arrangements (27 July 2017) (together, the Action 2 Recommendations), HMRC guidance at INTM550020 also confirms that the UK hybrids legislation is intentionally broader than the OECD recommendations in certain areas, so the outcomes may diverge from those under the OECD recommendations.

One illustration is chapter 7, which addresses D/NI mismatches arising where a hybrid payee is not within the charge to tax in any jurisdiction. With effect from 1...

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Web page updated on 22/05/2026

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