: HMRC published last week draft guidance on hybrid instruments and other mismatches.  The draft guidance is provided to assist understanding of the application of the hybrids mismatch legislation, which take effect from 1 January 2017. The examples in the draft guidance include a selection of those contained within the OECD Final Report on Neutralising the Effects of Hybrid Mismatch Arrangements, with additional examples dealing with hybrid transfers and permanent establishments. Given that some changes to the legislation were adopted in the report stage of the Finance Bill and the complexity of the new rules, HMRC is offering the opportunity to comment on the guidance. AIMA is considering whether a submission should be made on behalf of the UK alternative investment management industry. Comments on the draft guidance are invited by 10 March 2017. For further information, please contact Paul Hale or Enrique Clemente.