Taxes Consolidation Act 1997 section 835AI

Application of Chapter 4

Section 835AI sets out the entities and transactions to which the anti-hybrid mismatch rules in this Chapter apply.

• The Chapter applies to any company within the charge to domestic tax.
• It covers transactions that give rise to a mismatch outcome between associated enterprises, between an entity's head office and its permanent establishment, or between two or more permanent establishments of the same entity.
• Transactions that are on-market hybrid transfers are excluded from the scope of this Chapter.
• The rules implement the Anti-Tax Avoidance Directives (ATADs) in respect of hybrid mismatch arrangements.