INTM555100 - Hybrids: hybrid payee (Chapter 7): counteraction: contents
Counteraction to address the hybrid payee deduction/non-inclusion mismatch is considered first in respect of the payer (the primary counteraction).
»Ê¹ÚÌåÓýapp second counteraction, against investors in the hybrid payee(s), applies if the payer is not within the charge to UK corporation tax.
»Ê¹ÚÌåÓýapp third counteraction, against an LLP that is a hybrid payee, applies if the primary counteraction and the secondary counteraction do not apply to address the mismatch.
Details of each of the counteractions are provided in the following pages.