This article is a follow-on from our article “Anti-Hybrid Legislation: Finance Act 2019”, which appeared in Irish Tax Review, 33/1 (2020). By way of background, Finance Act 2019 introduced broad-ranging anti-hybrid provisions to Irish tax legislation, which apply in respect of all deductible payments made or arising on or after 1 January 2020. The primary effect of the anti-hybrid provisions is that, where they apply, a tax deduction can be denied in respect of payments made by Irish-resident companies, or Irish branches, that give rise to a hybrid mismatch.
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