Taxes Consolidation Act 1997 section 835AVC

Application (Chapter 10A)

Section 835AVC sets out the entities and outcomes to which the reverse hybrid mismatch rules in this Chapter apply.

• The Chapter applies to a reverse hybrid entity that has at least one relevant participator.
• Collective investment schemes are excluded, even if they would otherwise meet the definition of a reverse hybrid entity.
• The Chapter also applies to a reverse hybrid mismatch outcome.
• Both conditions — the entity and the mismatch outcome — must be present for the rules to operate.