New regulations amend hybrid capital instruments rules, for corporation tax relief on coupon payments on regulatory capital securities, used by banks and insurers.
Since 1 January 2019, the ‘hybrid capital instruments’ rules are relied upon by many banks and insurers to give corporation tax relief for the coupon payments on regulatory capital securities. These rules have recently been amended by the Taxation of Hybrid Capital Instruments (Amendment of Section 475C of the Corporation Tax Act 2009) Regulations 2019, SI 2019/1250.
The regulations make the following amendments to the hybrid capital instruments rules:
HMRC have also updated the corporate finance manual (CFM) with new guidance on the hybrid capital instruments rules introduced by Finance Act 2019.
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