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.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.