[CFM37870] CFM37870 – Loan relationships: hybrid capital instruments: tax rules – interaction with other rules
The new rules introduced by FA19/Sch20 contain some specific provisions on how hybrid capital instruments (HCI) that meet the definition in CTA09/S475C are treated for tax purposes (see CFM37860). This section of the guidance considers the application of other tax rules to these instruments. It also applies to non-HCI instruments previously covered by the Regulated Capital Securities (RCS) Regulations (CFM37890) and other non-HCI instruments issued to meet regulatory or other legal requirements.
The following points are covered in this section:
In addition, information on interactions with Stamp Duty and Stamp Duty Reserve Tax can be found at STSM021245A.