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The tax anti-hybrid rules paper

Published on 16 Mar 17 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • the tax anti-hybrid rules
  • are we alone?
  • how did we get here?
  • the Board's report
  • when will the rules apply?
  • do the rules apply to me? are there exceptions?

Author profile

Karen Payne CTA
Karen, CTA, was appointed as the inaugural Chief Executive Officer of the Board of Taxation, effective 31 March 2016. She is also a Member of the Board of Taxation, appointed in May 2015. She chaired the Board’s working group that advised on the implementation of the OECD hybrid mismatch rules – both generally and specifically in relation to regulatory capital. Karen was a member of the Board of Taxation advisory panel and assisted with the reviews of tax arrangements for managed investment trusts, venture capital limited partnerships, collective investment vehicles , the investment manager regime and the arm’s-length debt test. Karen was previously a Partner at Minter Ellison focusing on international and corporate taxes for the financial services industry, and mining, energy and utilities sectors. Karen has assisted domestic and international corporates and funds (equity, infrastructure, property, private equity and venture capital) with advice on structure, M&A and taxation due diligence. - Current at 09 December 2017
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This was presented at 32nd National Convention .

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