House of Commons · Public Bill Committee
- Sitting 2
14 December 2021
Proposed by Lucy Frazer Con South East Cambridgeshire
Summarised by AI from the official record, so it can contain mistakes.
At a glance
Key points
- Clause 26 addresses changes to corporation tax rules for hybrids and other mismatches.
- The amendment aims to ensure proportionate treatment of transparent entities.
- The Government consulted extensively with stakeholders before proposing the amendment.
Issue summary
Clause 26 addresses changes to corporation tax rules for hybrids and other mismatches to ensure proportionate treatment of certain types of transparent entities.
Action requested
The Government is proposing a technical amendment based on extensive consultation with stakeholders to align the treatment of transparent entities with partnerships in hybrid and mismatch rules, ensuring robustness against international tax planning without being overly harsh.
Key facts
- The UK implemented anti-hybrid rules in 2017, following OECD recommendations.
- A wide-ranging consultation was launched at Budget 2020 to review the area of legislation.
- Several amendments were made to the rules in the Finance Act 2021 but a specific change for transparent entities was withdrawn to allow additional time for stakeholder consultation.
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