Revenue eBrief No. 068/21 – Anti-hybrid guidance

Revenue eBrief No. 068/21

29 March 2021

Anti-hybrid guidance

Tax and Duty Manual Part 35C-00-01, which provides guidance on the anti-hybrid rules, has been updated to include:

  • amendments made by Finance Act 2020 to how the anti-hybrid rules apply to worldwide systems of taxation,
  • key terms used in the anti-hybrid rules such as “payee”, “reasonable to consider” and “associated enterprise”, and
  • the “imported mismatch” rule.

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