Taxes Consolidation Act 1997 section 835AE

Application of Chapter 3

Section 835AE sets out the scope of the anti-hybrid mismatch rules by identifying the entities and transactions to which the Chapter applies.

• The Chapter applies to any entity within the charge to foreign tax or corporation tax.
• It covers transactions that give rise to a mismatch outcome between entities that are associated enterprises.
• Transactions between an entity's head office and a permanent establishment of that entity are also within scope.
• Transactions between two or more permanent establishments of the same entity are equally caught by the rules.