Guidance
Hybrid capital instruments technical note
This technical note is about new tax rules for loan relationships that are hybrid capital instruments.
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The purpose of this technical note is to explain the new tax rules for loan relationships that are hybrid capital instruments.
This note has been updated to add paragraph 2.4. The new paragraph explains the government’s intention to amend legislation introduced in Finance Act 2019, to address concerns about the way it applies to instruments with a takeover or change of control provision.
Updates to this page
Published 29 October 2018
Last updated 18 April 2019 + show all updates
Last updated 18 April 2019 + show all updates
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Paragraph 2.4, about a proposed amendment to legislation, has been added to the technical note.
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First published.