Hybrid - Payers, Payees & Instruments - Live at Your Desk

Introduction

Hybrid mismatches occur where there are inconsistencies between the tax treatment of financial instruments, as well as where the status of the payer and payee may also vary between international tax jurisdictions.

This new virtual classroom seminar will look in detail at the hybrid rules which have been subject to substantial changes nearly every year since they were introduced in 2016.

Hybrid instruments also pose particular challenges to advisors who may be responsible for only one country’s tax compliance but need to have some knowledge of the counterparty’s position in order to make a judgment on the appropriate tax treatment.

Ideal for anyone who advises clients on international operations, this session aims to combine both the principles of hybrid rules with worked examples to illustrate the key issues in practice.

What You Will Learn

This live and interactive session will cover the following:

• Hybrid payers
• Dual resident companies as well as permanent establishment of foreign branches
• Hybrid payees
• Recipients of payments which may have inconsistent tax treatment across borders
• Hybrid instruments
• Identifying instruments which have different tax treatments in different jurisdictions
• Third party transactions
• How the legislation deals with transactions routed through different jurisdictions and the effect of the imported mismatch rules
• Interaction with other tax legislation
• How transfer pricing and unallowable purpose rules interact with the hybrid rules

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.