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Home / Simons-Taxes /Corporate tax /Part D4 Overseas issues /Division D4.7 Hybrid entities /Tax arbitrage / D4.744 Tax arbitrage—notices
Commentary

D4.744 Tax arbitrage—notices

Corporate tax

The provisions in this article were repealed from 1 January 2017. From 1 January 2017, the rules dealing with hybrid and other mismatches apply; see D4.701 onwards. The latter rules were introduced as part of the OECD BEPS action plan on international corporate tax avoidance.

If HMRC gives a notice under either of the provisions described in D4.741 and D4.743 (referred to in the legislation as 'Part 6 notices') the company has various options, depending upon when the notice was issued, as detailed below:

  1. Ìý

    •ÌýÌýÌýÌý Part 6 notice issued before the company has made its tax return for the specified accounting period. The company may:

    1. Ìý

      –ÌýÌýÌýÌý may make a return at any time before the end of a 90 day period (beginning with the day on which the notice was given) which disregards the notice, and

    2. Ìý

      –ÌýÌýÌýÌý at any time before the end of the same 90 day period, amend the return in order

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