The Treasury made the Taxation of Regulatory Capital Securities Regulations 2013 (‘RCS Regulations’) to provide certainty of tax treatment for certain regulatory capital securities (‘RCS’) issued by banks and insurers. The RCS Regulations were introduced to coincide with the date the EU Capital Requirements Regulations (CRR) had legal effect. The tax regulations ensured that the tax rules were consistent with the regulatory framework

The RCS Regulations were revoked with effect from 1 January 2019 and new rules introduced for hybrid capital instruments see CFM37810.

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