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INTM Guidance - GOV.UK

1 OFFICIAL INTM Guidance Hybrid and Other Mismatches The following Guidance is provided to assist understanding of the application of the hybrid mismatch legislation, which came into effect on 1 January 2017. Many of the examples are based upon a selection of those contained within the OECD Final Report on Neutralising the Effects of Hybrid Mismatch Arrangements , with additional examples dealing with hybrid transfers and permanent establishments. These pages form part of the International Manual. They contain Guidance prepared for HMRC staff and are published in accordance with the Freedom of Information Act 2000 and the HMRC Publication Scheme. You should not assume that the Guidance is comprehensive or that it will provide a definitive answer in every case.

In 2013 the OECD and G20 countries adopted a 15-point Action Plan to address Base Erosion Profit Shifting (BEPS). The Action Plan aims to ensure that profits are taxed where the economic activities generating the profits are performed and where value is created, and to counter aggressive tax planning aimed at base eroding a jurisdiction.

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CbC Reporting — BEPS Action 13 Introduction On 19 July 2013 the OECD released an Action Plan on Base Erosion and Profit Shifting (BEPS). The Action Plan covered 15 specific Actions. Action 13 focuses on a company’s global value chain and transfer pricing policy and documentation. It aims to

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