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PwC response to public consultation on Anti-Reverse Hybrid mismatches

02 September, 2021

The Irish Department of Finance recently ran a public consultation on the Anti-Reverse Hybrid Rule. The consultation closed on 3 August 2021.

Interested stakeholders were invited to submit their views on possible approaches to some of the technical aspects of the anti-reverse hybrid rule in the context of the following:

  • Reverse hybrid legislative framework: Input as regards the framing of the anti-reverse hybrid rule. Feedback was specifically sought regarding the suggested definition of a reverse hybrid mismatch outcome, the scope of application, mechanics of the charge to tax and interaction with double tax treaty provisions where the reverse hybrid mismatch rule applies.
  • Collective Investment Vehicles (CIVs): Input as regards the carve out for CIVs. In this context, feedback was specifically sought regarding the transposition of various terms or definitions, such as; "Collective Investment Vehicles", "widely held", "diversified portfolio of securities", "associated entities" and the appropriateness of providing for these terms or definitions in Irish domestic law. In addition, feedback was sought regarding the application of a purpose test.
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Colin Farrell

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 6345

Denis Harrington

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 8629

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