Hybrid Mismatch Arrangements in the UK - Practical Implications for Cross-Border Structures

Introduction

The UK’s hybrid mismatch rules under Part 6A CTA 2010 were introduced to counteract tax advantages arising from differences in the tax treatment of instruments or entities across jurisdictions, in line with OECD BEPS Action 2.

These rules are complex, and their scope is wide, affecting hybrid entities, financing structures, and certain imported mismatch arrangements.

Misapplication or oversight can lead to unexpected UK tax charges, denied deductions, or double taxation.

This webinar will provide a structured review of the UK rules, practical compliance points, and examples from real-world scenarios, helping you identify risks early and ensure alignment between UK tax treatment and overseas positions.

What You Will Learn

On completion of this webinar, you will be able to:

• Identify the main categories of hybrid mismatch outcomes covered by the UK rules (deduction/non-inclusion, double deduction, etc.)
• Understand the scope and interaction of UK legislation with OECD BEPS recommendations and EU ATAD measures
• Recognise the difference between hybrid financial instruments, hybrid entities, and imported mismatches
• Navigate the key statutory provisions in Part 6A CTA 2010 and related HMRC guidance
• Apply the rules to common scenarios, including UK inbound financing and multi-jurisdictional group structures
• Manage interaction with double tax treaties and domestic anti-avoidance provisions
• Implement practical compliance steps, including documentation and evidence to support UK tax filings
• Avoid common pitfalls and understand the potential penalties for non-compliance

This pre-recorded webinar will be available to view from Monday 23rd February 2026

Alternatively, you can gain access to this webinar and 1,900+ others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.