Taxes Consolidation Act 1997 section 835AX

Order of application

Section 835AX sets out the order of application of the anti-hybrid mismatch rules in this Part relative to other provisions of the Tax Acts and the Capital Gains Tax Acts.

• This Part applies after all other provisions of the Tax Acts and the Capital Gains Tax Acts, but before section 811C.
• A mismatch outcome may only be neutralised once under this Part.
• Where more than one Chapter could apply to the same mismatch, only one Chapter may counteract it.
• This ordering ensures the anti-hybrid rules operate as a final layer of adjustment, subject only to the general anti-avoidance rule in section 811C.