Categories:Tax,UK

Tax deduction for regulatory capital

HMRC has issued long-awaited draft regulations aimed at providing a new tax regime for regulatory capital issued in line with the Capital Requirements Regulation (CRR) element of the Capital Requirements Directive IV (CRD IV) package of regulatory reform. The regulations are to be enacted under Finance Act 2012.

The draft regulations provide for a generous new tax regime for Additional Tier 1 instruments and Tier 2 instruments issued by qualifying issuers in compliance with CRR. An instrument benefiting from the new regime is referred to as a ‘regulatory capital security’. Specific provisions in the Finance Act 2013 dealing with Tier 2 instruments will be repealed.

They will be credit institutions, investment firms (both as defined in the CRR) or the parent undertakings of either. This follows because CRR, which requires Additional Tier 1 instruments and Tier 2 instruments to comply with certain conditions, applies only to credit institutions and investment firms…

If you are registered and logged in to the site, click on the link below to read the rest of the Allen & Overy briefing. If not, please register or sign in with your details below.

Briefings from Allen & Overy

View more briefings from Allen & Overy

Analysis from The Lawyer

View more analysis from The Lawyer

Overview

One Bishops Square
London
E1 6AD
UK
http://www.allenovery.com

Turnover (£m): 1,189.00
No. of lawyers: 2,304
Jurisdiction: UK
No. of offices: 11
No. of qualified lawyers: 273

Jobs