ATAD

The exclusion from the hybrid mismatch rules for regulatory capital instruments has been narrowed to comply with ATAD. 

Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.

It seems unlikely, writes Heather Self (Blick Rothenberg).

Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions