Taxes Consolidation Act 1997 section 835AT

Application of Chapter 9

Section 835AT sets out the entities and transactions to which the structured arrangement anti-hybrid rules in this Chapter apply.

• The Chapter applies to any company within the charge to Irish tax.
• It overrides the associated enterprise requirements in the other anti-hybrid chapters (sections 835AC, 835AE, 835AI and 835AK).
• The Chapter catches mismatch outcomes that arise under a structured arrangement, i.e. an arrangement designed to produce the mismatch.
• This ensures the anti-hybrid rules apply to structured arrangements regardless of whether the parties are associated enterprises.