Related Commentary  Related HMRC Manuals

475C(1)  For the purposes of this Part, a loan relationship is a “hybrid capital instrument” for an accounting period of the debtor if–

(a)the loan relationship makes provision under which the debtor is entitled to defer or cancel a payment of interest under the loan relationship,

(b)the loan relationship has no other significant equity features, and

(c)the debtor has made an election in respect of the loan relationship which has effect for the period.

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