All the mismatch arrangements described above involve
payments. The amount of a payment is measured in money. While
differences in the way two jurisdictions value a payment can give rise to
mismatches, differences in the valuation of money itself are not within the
scope of the hybrid mismatch rule. For example, gains and losses from
foreign currency fluctuations on a loan are differences in the value of money
(rather than the amount of money) payable under that loan. This kind of
mismatch will not give rise to a D/NI outcome provided the proportion of
the interest and principal payable under the loan is the same under the laws
of both jurisdictions.