Taxes Consolidation Act 1997 section 835AK

Application of Chapter 5

Section 835AK sets out the scope of the hybrid entity mismatch rules, identifying the types of transactions and entities to which this chapter applies.

• The chapter applies to 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.
• Section 835AL, which deals with payments to a hybrid entity resulting in a deduction without inclusion mismatch, applies to companies within the charge to corporation tax.
• Section 835AM, which deals with payments by a hybrid entity resulting in a deduction without inclusion mismatch, applies to companies within the charge to foreign tax or corporation tax.
• The rules implement the Anti-Tax Avoidance Directives (ATADs) requirements on hybrid entity mismatches.