Executive summary
On 12 November 2020, the United Kingdom (UK) Government published its response to a consultation document alongside limited draft legislation for some changes proposed to the UK hybrid and other mismatches regime.
In particular, HM Revenue & Customs (HMRC) has accepted that many of the rules as currently drafted have a disproportionate outcome. In order to address the issues which have been raised, legislative change is required, some of which will have retrospective effect b…