{"corpusVersion":"2026-07-28.2","exampleProfile":{"archetypeIds":["archetype-private-company"],"asOf":"2026-07-28","assertions":[{"basis":"The UK company remains a body corporate separate from its sole owner.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic company incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"hybrid-uk-company","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16","src-hmrc-hybrid-entities"],"status":"established"},{"basis":"The incorporated company is the UK Corporation Tax subject for the synthetic trade.","classificationId":"attribution:subject-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United Kingdom","ruleset":"UK company-tax treatment as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities","src-hmrc-intm180010"],"status":"established"},{"basis":"The example assumes a valid owner-level US federal classification; it does not ask the UK to follow that classification.","classificationId":"attribution:owner-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-01-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United States","ruleset":"US entity-classification rules and the synthetic valid classification as at 2026-07-28","subjectRef":"hybrid-sole-owner","taxOrRegime":"US federal income tax"},"sourceIds":["src-irs-entity-classification-2026","src-hmrc-hybrid-entities"],"status":"conditional"},{"basis":"The company, rather than its owner acting personally, carries on the synthetic trade under UK law.","classificationId":"capacity:company-trader","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade","jurisdiction":"United Kingdom","ruleset":"UK Corporation Tax framework as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities"],"status":"established"},{"basis":"UK incorporation supplies the normal domestic residence rule, subject to statutory and treaty exceptions.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"UK-incorporated synthetic company","jurisdiction":"United Kingdom","ruleset":"UK incorporation residence rule and treaty exceptions as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax residence"},"sourceIds":["src-hmrc-intm120040"],"status":"conditional"},{"basis":"The example assumes an available and valid US election from the stated date; the election does not change the UK legal form.","classificationId":"registration:classification-election","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-01-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic valid classification election","jurisdiction":"United States","ruleset":"US check-the-box rules as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"US federal entity classification"},"sourceIds":["src-irs-entity-classification-2026","src-us-check-box-1996"],"status":"conditional"},{"basis":"The synthetic facts state one natural-person ultimate owner; this role is separate from both countries' tax-attribution results.","classificationId":"control:beneficial-owner","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic sole ownership and ultimate control","jurisdiction":"United Kingdom","ruleset":"FATF legal-person guidance subject to UK implementation","subjectRef":"hybrid-sole-owner","taxOrRegime":"Beneficial ownership"},"sourceIds":["src-fatf-legal-persons-2023"],"status":"established"},{"basis":"No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:financial-institution","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:active-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:passive-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"The company remains the UK taxpayer and filer even though the US federal attribution in this example points to its owner.","classificationId":"obligation:taxpayer-and-filer","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade return","jurisdiction":"United Kingdom","ruleset":"UK Corporation Tax framework as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities"],"status":"established"}],"id":"example-uk-company-us-disregarded","jurisdiction":"United Kingdom and United States","label":"UK company with a different US federal tax classification","notDetermined":["Whether any real company is eligible for or made a US classification election.","Any hybrid-mismatch, treaty, reporting or filing consequence.","Any amount of tax."],"reviewTriggers":["Verify that the foreign classification or election is legally available and effective.","Read the exact UK charge, US federal rule and any hybrid-mismatch or treaty provision.","Do not infer reporting, residence or beneficial ownership from either tax classification."],"subjects":[{"id":"hybrid-uk-company","kind":"private-limited-company","label":"Synthetic UK company"},{"id":"hybrid-sole-owner","kind":"natural-person-owner","label":"Synthetic sole natural-person owner"}],"summary":"A synthetic UK-incorporated company carries on a software trade. The example assumes a valid US federal classification under which its sole owner is charged on the same trade profits while the company remains the UK Corporation Tax subject."},"interpretation":{"boundary":{"filingOrSubmission":false,"legalAdvice":false,"personalFactsAccepted":false,"singleLabelSufficient":false,"syntheticExample":true},"example":{"archetypeIds":["archetype-private-company"],"asOf":"2026-07-28","id":"example-uk-company-us-disregarded","jurisdiction":"United Kingdom and United States","label":"UK company with a different US federal tax classification","subjects":[{"id":"hybrid-sole-owner","kind":"natural-person-owner","label":"Synthetic sole natural-person owner"},{"id":"hybrid-uk-company","kind":"private-limited-company","label":"Synthetic UK company"}],"summary":"A synthetic UK-incorporated company carries on a software trade. The example assumes a valid US federal classification under which its sole owner is charged on the same trade profits while the company remains the UK Corporation Tax subject."},"identityVector":[{"assertions":[{"basis":"The UK company remains a body corporate separate from its sole owner.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic company incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"hybrid-uk-company","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16","src-hmrc-hybrid-entities"],"status":"established"}],"dimensionId":"legal-existence","dimensionLabel":"Legal existence and form"},{"assertions":[{"basis":"The example assumes a valid owner-level US federal classification; it does not ask the UK to follow that classification.","classificationId":"attribution:owner-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-01-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United States","ruleset":"US entity-classification rules and the synthetic valid classification as at 2026-07-28","subjectRef":"hybrid-sole-owner","taxOrRegime":"US federal income tax"},"sourceIds":["src-irs-entity-classification-2026","src-hmrc-hybrid-entities"],"status":"conditional"},{"basis":"The incorporated company is the UK Corporation Tax subject for the synthetic trade.","classificationId":"attribution:subject-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United Kingdom","ruleset":"UK company-tax treatment as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities","src-hmrc-intm180010"],"status":"established"}],"dimensionId":"tax-attribution","dimensionLabel":"Tax attribution and charge"},{"assertions":[{"basis":"The company, rather than its owner acting personally, carries on the synthetic trade under UK law.","classificationId":"capacity:company-trader","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade","jurisdiction":"United Kingdom","ruleset":"UK Corporation Tax framework as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities"],"status":"established"}],"dimensionId":"capacity-activity","dimensionLabel":"Capacity and activity"},{"assertions":[{"basis":"UK incorporation supplies the normal domestic residence rule, subject to statutory and treaty exceptions.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"UK-incorporated synthetic company","jurisdiction":"United Kingdom","ruleset":"UK incorporation residence rule and treaty exceptions as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax residence"},"sourceIds":["src-hmrc-intm120040"],"status":"conditional"}],"dimensionId":"residence-nexus","dimensionLabel":"Residence and territorial nexus"},{"assertions":[{"basis":"The example assumes an available and valid US election from the stated date; the election does not change the UK legal form.","classificationId":"registration:classification-election","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-01-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic valid classification election","jurisdiction":"United States","ruleset":"US check-the-box rules as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"US federal entity classification"},"sourceIds":["src-irs-entity-classification-2026","src-us-check-box-1996"],"status":"conditional"}],"dimensionId":"registration-grouping","dimensionLabel":"Registration, election and grouping"},{"assertions":[{"basis":"The synthetic facts state one natural-person ultimate owner; this role is separate from both countries' tax-attribution results.","classificationId":"control:beneficial-owner","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic sole ownership and ultimate control","jurisdiction":"United Kingdom","ruleset":"FATF legal-person guidance subject to UK implementation","subjectRef":"hybrid-sole-owner","taxOrRegime":"Beneficial ownership"},"sourceIds":["src-fatf-legal-persons-2023"],"status":"established"}],"dimensionId":"ownership-control","dimensionLabel":"Ownership, control and benefit"},{"assertions":[{"basis":"No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:active-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:financial-institution","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:passive-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"}],"dimensionId":"reporting-classification","dimensionLabel":"Reporting classification"},{"assertions":[{"basis":"The company remains the UK taxpayer and filer even though the US federal attribution in this example points to its owner.","classificationId":"obligation:taxpayer-and-filer","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade return","jurisdiction":"United Kingdom","ruleset":"UK Corporation Tax framework as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities"],"status":"established"}],"dimensionId":"obligation-role","dimensionLabel":"Filing, payment and withholding role"}],"notDetermined":["Whether any real company is eligible for or made a US classification election.","Any hybrid-mismatch, treaty, reporting or filing consequence.","Any amount of tax."],"overlaps":[{"dangerousShortcut":"Forcing one country-wide entity type or treating the mismatch as dirty data.","id":"overlap-cross-border-hybrid","label":"One legal form, different countries' tax classifications","matchedAssertions":{"legal-entity":{"classificationId":"legal:body-corporate","dimensionId":"legal-existence","scope":{"activityOrContext":"Synthetic company incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"hybrid-uk-company","taxOrRegime":"Company law"},"status":"established"},"owner-level-charge":{"classificationId":"attribution:owner-level","dimensionId":"tax-attribution","scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United States","ruleset":"US entity-classification rules and the synthetic valid classification as at 2026-07-28","subjectRef":"hybrid-sole-owner","taxOrRegime":"US federal income tax"},"status":"conditional"},"subject-level-charge":{"classificationId":"attribution:subject-level","dimensionId":"tax-attribution","scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United Kingdom","ruleset":"UK company-tax treatment as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"status":"established"}},"meaning":"A jurisdiction can treat a body as separate while another looks through it or follows an election. Both classifications can be correct in their own scopes.","sourceIds":["src-hmrc-hybrid-entities","src-hmrc-intm180010","src-irs-entity-classification-2026","src-us-check-box-1996"],"status":"conditional"}],"review":{"conflictingDimensionIds":[],"inactiveAssertionIds":[],"reasons":["A foreign entity, election or disregarded status appears.","Assertion reporting-classification:reporting:active-nfe@hybrid-uk-company|United Kingdom and United States|CRS and FATCA|Hypothetical financial account|Applicable reporting regime and domestic implementation is unknown.","Assertion reporting-classification:reporting:financial-institution@hybrid-uk-company|United Kingdom and United States|CRS and FATCA|Hypothetical financial account|Applicable reporting regime and domestic implementation is unknown.","Assertion reporting-classification:reporting:passive-nfe@hybrid-uk-company|United Kingdom and United States|CRS and FATCA|Hypothetical financial account|Applicable reporting regime and domestic implementation is unknown.","Do not infer reporting, residence or beneficial ownership from either tax classification.","No active established, conditional, disputed or not-applicable assertion covers reporting-classification.","Overlap overlap-cross-border-hybrid is conditional on at least one assertion.","Payments cross between differently classified entities.","Read the exact UK charge, US federal rule and any hybrid-mismatch or treaty provision.","Treaty entitlement or hybrid-mismatch rules may matter.","Verify that the foreign classification or election is legally available and effective."],"status":"needs-review"},"schema":"taxsorted.tax-identity-interpretation/1","sourceIds":["src-companies-act-2006-s16","src-fatf-legal-persons-2023","src-hmrc-hybrid-entities","src-hmrc-intm120040","src-hmrc-intm180010","src-irs-entity-classification-2026","src-oecd-crs-2025","src-us-check-box-1996"],"unresolvedDimensionIds":["reporting-classification"]},"schema":"taxsorted.uk.tax-identity-example-detail/1","sources":[{"authorityLevel":"legislation","id":"src-companies-act-2006-s16","jurisdiction":"United Kingdom","limitations":["Corporate existence does not settle residence, beneficial ownership, VAT grouping or foreign tax classification."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["Registration forms a body corporate capable of exercising the functions of an incorporated company."],"title":"Companies Act 2006, section 16","url":"https://www.legislation.gov.uk/ukpga/2006/46/section/16"},{"authorityLevel":"official-guidance","id":"src-hmrc-intm180010","jurisdiction":"United Kingdom","limitations":["A general HMRC view can vary after examining a specific foreign entity's constitution and facts."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Transparent and opaque are informal labels for who is liable on what income or gains.","The exact UK tax provision must be considered rather than applying one entity-wide label."],"title":"INTM180010: Foreign entity classification","url":"https://www.gov.uk/hmrc-internal-manuals/international-manual/intm180010"},{"authorityLevel":"official-guidance","id":"src-hmrc-intm120040","jurisdiction":"United Kingdom","limitations":["Treaty rules and the full statutory exceptions must be checked."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Subject to stated exceptions, a UK-incorporated company is UK resident for corporation tax."],"title":"INTM120040: Company residence incorporation rule","url":"https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120040"},{"authorityLevel":"model-standard","id":"src-oecd-crs-2025","jurisdiction":"International","limitations":["Domestic implementation and effective dates control reporting obligations.","The 2025 consolidation includes amendments whose first exchanges are expected later."],"publisher":"OECD","retrievedAt":"2026-07-28","supports":["CRS Entity, Financial Institution, Active NFE, Passive NFE and Controlling Person are separate reporting classifications.","A trust's controlling-person roles include settlors, trustees, protectors, beneficiaries or classes and other persons exercising ultimate effective control."],"title":"Consolidated text of the Common Reporting Standard 2025","url":"https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/04/consolidated-text-of-the-common-reporting-standard-2025_e478bc04/055664b1-en.pdf"},{"authorityLevel":"model-standard","id":"src-fatf-legal-persons-2023","jurisdiction":"International","limitations":["FATF standards require domestic implementation and do not decide a person's tax liability."],"publisher":"Financial Action Task Force","retrievedAt":"2026-07-28","supports":["Beneficial owners are natural persons who ultimately own or control a legal person.","Legal ownership and ultimate beneficial ownership can differ.","Accurate, adequate and up-to-date information needs more than one source."],"title":"Guidance on Beneficial Ownership of Legal Persons","url":"https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf"},{"authorityLevel":"official-guidance","id":"src-irs-entity-classification-2026","jurisdiction":"United States","limitations":["Disregarded treatment has charge-specific exceptions and does not determine UK treatment."],"publisher":"Internal Revenue Service","retrievedAt":"2026-07-28","supports":["Eligible entities can have a federal tax classification different from their state-law form.","A single-owner eligible entity can be disregarded or elect association treatment."],"title":"Classification of taxpayers for US tax purposes","url":"https://www.irs.gov/individuals/international-taxpayers/classification-of-taxpayers-for-us-tax-purposes"},{"authorityLevel":"regulation-or-directive","id":"src-us-check-box-1996","jurisdiction":"United States","limitations":["Later amendments and the current Code and regulations must be checked."],"publisher":"US Department of the Treasury","retrievedAt":"2026-07-28","supports":["The check-the-box entity-classification regulations generally became applicable in 1997."],"title":"Treasury Decision 8697","url":"https://www.govinfo.gov/content/pkg/FR-1996-12-18/pdf/96-31997.pdf"},{"authorityLevel":"official-guidance","id":"src-hmrc-hybrid-entities","jurisdiction":"United Kingdom","limitations":["Diagram notation communicates claims; it does not prove them."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["A UK company can be a company where incorporated and disregarded for US tax.","A UK LLP can be transparent in the UK and treated as a corporation elsewhere.","Incorporation and tax residence belong on separate parts of a group map."],"title":"Help with sharing group structure information","url":"https://www.gov.uk/government/publications/help-with-sharing-group-structure-information-gfc17/help-with-sharing-group-structure-information"}]}