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Debt-like or Equity-like?

 
Chris Bates tax partner and Judy Harrison senior associate Norton Rose LLP discuss changes to the tax treatment of preference shares
 
The government has published draft legislation which makes technical changes to the corporation tax rules setting out what constitutes a group of companies. The broad policy behind these changes is to help banking groups that have issued non-cumulative preference shares in order to raise Tier 1 capital to ride out the financial crisis. In reality the changes apply to all groups of companies which have issued or intend to issue preference shares.
 
Although this legislation is helpful to banking groups many of which are struggling to raise capital as a result of the credit crunch it is slightly disappointing that the change is...

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