Are the rules on the taxation of perpetual debt in perpetual motion? William Watson reviews the state of play.
I fear that many readers will have missed the big tax story in last month’s Budget. As the editor of Tax Journal was kind enough to point out to me when I suggested the subject for this article The Times broke the news on 1 April: ‘Chancellor to banks’ rescue with secret £1bn tax break’.
There followed two full columns devoted to an announcement which appeared in para 2.26 of the Overview of Tax Legislation and Rates published on 20 March. This read as follows:
‘The government will following the conclusion of the capital requirements directive IV issue secondary legislation to confirm and ensure that banks’ additional tier one debt capital instruments...
