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General comment

Several of the following examples correspond to examples included in the Final Report on Neutralising the Effects of Hybrid Mismatch Arrangements published by the Organisation for Economic Cooperation and Development (OECD) on 5 October 2015. These illustrate scenarios that could include a mismatch where a financial instrument issued by a company in one tax jurisdiction is held by a company in another, but which might not necessarily give rise to a mismatch where one of the jurisdictions is the UK.

Nevertheless, these examples are included to demonstrate the principles underlying the relevant parts of the hybrid and other mismatch legislation.

Additional examples reflecting more common commercial use of financial instruments in the UK may be considered for inclusion in later versions of this guidance.