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Overcoming the Challenges of Hybrid Mismatch Rules

Writer: Angelo ChirulliAngelo Chirulli

Family offices

Are hybrid mismatch rules creating uncertainty for your business? As tax authorities tighten regulations, navigating these rules has become a critical priority for companies engaged in international operations.


Key Challenges for Businesses

  1. Unintended Tax Liabilities: Payments within multinational groups can trigger rules unexpectedly, even when no tax advantage was intended.

  2. Balancing Compliance and Operations: Aligning tax compliance with business goals requires careful coordination between tax, legal, and operational teams.

  3. Interactions with Other Rules: Hybrid mismatch rules often overlap with measures like Controlled Foreign Company (CFC) rules and interest restrictions, creating a cumulative compliance burden.


How to Navigate These Challenges

  • Conduct a Risk Assessment: Identify transactions and entities that may be affected by hybrid mismatch rules.

  • Review Financing Structures: Evaluate hybrid instruments and restructure where necessary to minimize risk.

  • Stay Updated: Monitor changes in legislation and case law globally to ensure ongoing compliance.


Why LEXeFISCAL?

At LEXeFISCAL, we specialize in:

  • Reviewing and restructuring financing arrangements to mitigate risks.

  • Ensuring compliance with hybrid mismatch rules and other anti-avoidance measures.

  • Developing strategies that balance tax efficiency with regulatory obligations.

If hybrid mismatch rules are impacting your business, proactive planning is essential to mitigate risks and ensure compliance. Let us help you navigate these complexities effectively.


Contact us today:

Tel: +44 (0)208 092 2111

 
 
 

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