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Hybrids
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Hybrids
HYBRIDS
UK loan structures: changes to the anti-hybrid rules
Matthew Mortimer
Kirsten Hunt
Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.
Legislation day: what you need to know
Rhiannon Kinghall Were
Lucy Urwin
Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) report.
Tax and the City review for May 2021
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Tax and the City review for February 2021
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
Tax and the City review for May 2020
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
International review for September 2019
Tim Sarson
Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.
Tax and the City review for May 2019
Zoe Andrews
Mike Lane
Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime. An HCI is a loan relationship under which the debtor (but not the...
The new regime for hybrid capital instruments
Mike Lane
Mike Lane (Slaughter and May) explains how the new rules might work in practice.
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3
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
Read all
C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
Stage One Creative Services Ltd v HMRC
Other cases that caught our eye: 13 December 2024
L v HMRC
A third route to exit: tax consequences of continuation fund transactions
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