SI 2019/1250 - The Taxation of Hybrid Capital Instruments (Amendment of Section 475C of the Corporation Tax Act 2009) Regulations 2019

Released 11 September 2019

SI 2019/1250 amends CTA 2009, s. 475C, with retrospective effect, to ensure rules relating to hybrid capital instruments work as intended.

The Taxation of Hybrid Capital Instruments (Amendment of Section 475C of the Corporation Tax Act 2009) Regulations 2019 amend the Corporation Tax Act 2009, s. 475C to ensure that the rules relating to hybrid capital instruments, introduced in the Finance Act 2019, Sch. 20, work as intended. Specifically, these amendments ensure that where a loan relationship includes a takeover or change of control provision which could result in a conversion into ordinary share capital of a company which (together with its associates) controls the debtor, that provision will not cause the loan relationship to fall outside of the rules. The regulations also provide for rules in relation to elections. FA 2019, Sch. 20 is deemed to always have had effect with the amendments made by these regulations. Authority for the retrospective effect is given by FA 2019, Sch. 20, para. 19(5). The regulations come into force on 4 November 2019.

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