INTM550090 - Hybrids: introduction: summary of Part 6A

Type	Mismatch Involving	Primary Response	Defensive Rule	Scope
D/NI	Chapter 3: Financial Instruments	Deny payer deduction	Include as ordinary income	Related parties and structured arrangements
D/NI	Chapter 4: Hybrid Transfers	Deny payer deduction	Include as ordinary income	Related parties and structured arrangements
D/NI	Chapter 5: Hybrid Payer	Deny payer deduction	Include as ordinary income	Control group and structured arrangements
D/NI	Chapter 6: Permanent Establishments	Deny deduction to UK PE	-	UK permanent establishments
D/NI	Chapter 7: Hybrid Payee	Deny payer deduction	Include as ordinary income of investor, then LLP	Control group and structured arrangements
D/NI	Chapter 8: Multinational Payee	Deny payer deduction	-	Control group and structured arrangements
DD	Chapter 9: Hybrid Entity	Deny investor deduction	Deny payer deduction	Related parties and structured arrangements
DD	Chapter 10: Dual Territory	Dual resident company: deny deduction / Multinational company: deny parent jurisdiction deduction	Multinational company: deny deduction to UK PE	Dual resident and multinational companies
D/NI / DD	Chapter 11: Imported Mismatches	Deny payer deduction	-	Control group and structured arrangements