William Watson explains why HMRC's June paper is welcome news.
At the beginning of May I co-wrote an article (‘Is a perpetual note debt for tax purposes?’ Tax Journal dated 4 May 2012) which considered whether a ‘perpetual’ note should be regarded as debt for tax purposes. It is not usually a good sign to be returning to a subject so soon. But HMRC has picked up the theme in a paper that is undated but was published on 26 June 2012 and is titled The current tax treatment of instruments designed to be compliant with Capital Requirements Directive 4. I am glad to say that it contains some good news.
The June paper also discusses the new form of regulatory capital that UK (and other EU) banks are expected to start issuing once the relevant legislation has come into force; this will consist of ‘additional tier...
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William Watson explains why HMRC's June paper is welcome news.
At the beginning of May I co-wrote an article (‘Is a perpetual note debt for tax purposes?’ Tax Journal dated 4 May 2012) which considered whether a ‘perpetual’ note should be regarded as debt for tax purposes. It is not usually a good sign to be returning to a subject so soon. But HMRC has picked up the theme in a paper that is undated but was published on 26 June 2012 and is titled The current tax treatment of instruments designed to be compliant with Capital Requirements Directive 4. I am glad to say that it contains some good news.
The June paper also discusses the new form of regulatory capital that UK (and other EU) banks are expected to start issuing once the relevant legislation has come into force; this will consist of ‘additional tier...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
