Understanding new U.K. hybrid mismatch rules

Understanding new U.K. hybrid mismatch rules

Part of a Baker Tilly and MHA MacIntyre Hudson U.K.-U.S. tax webinar series

Baker Tilly International independent member firms — Baker Tilly in the U.S. and MHA MacIntyre Hudson in the U.K. — actively address the needs of their clients that have cross-border business and investments. Our goal is to strengthen their financial position while enhancing their ability to stay compliant with local tax law and business regulations. To that end, our international tax specialists are hosting a series of webinars on tax considerations for U.S. entities doing business within the U.K.

In this presentation, a general overview of new U.K. hybrid mismatch rules is provided, with a particular focus on understanding the potential impact of these new rules on U.S. groups holding U.K. subsidiaries which have been disregarded for U.S. tax purposes. Our international tax specialists discuss:

  • Current rules on hybrid mismatches
  • U.S.- U.K. tax treaty impact
  • Anti-Tax Avoidance Directive (ATAD)/OECD’s BEPS recommendations
  • The key risks and opportunities


  • Jim LawsonEast Region Leader – International Tax, Baker Tilly
  • Chris Denning, Corporate and International Tax Partner, MHA MacIntyre Hudson
  • Alison Conley, Corporate and International Tax Partner, MHA MacIntyre Hudson

For more information on this topic, or to learn how Baker Tilly tax specialists can help, contact our team.

View the first webinar in our series, Brexit: A U.S. Perspective >

The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely.  The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.

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