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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Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime.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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EDITOR'S PICK
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
1 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2 /7
2024: that was the year that was
Jemma Dick
3 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
4 /7
The tractor tax
Stuart Maggs
5 /7
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
6 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
7 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
NEWS
Read all
HMRC manual changes: 17 January 2025
Tax investigations windfall for Chancellor
EU FASTER Directive published
CIOT highlights risks of proposed NICs changes
Making Tax Digital: updated guidance and new awareness events
CASES
Read all
HMRC v Yorkshire Agricultural Society
The Mersey Docks and Harbour Company Ltd v HMRC
Bridgecom International Ltd v HMRC
Other cases that caught our eye: 17 January 2025
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
IN BRIEF
Read all
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
MOST READ
Read all
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
M R Currell Ltd v HMRC
Chemidex Generics Ltd v HMRC
NHS Mid & South Essex ICB and others v HMRC
Tax exemption for LGBT Financial Recognition Scheme payments