The Hybrid and Other Mismatches (Financial Instruments: Excluded Instruments) Regulations, SI 2019/1345, introduce further requirements with effect from 1 January 2020 to preserve the exemption in respect of specific regulatory capital securities held by banks from the anti-avoidance rules on hybrids and other mismatches. The changes are needed to ensure the UK rules comply with minimum standards under the EU anti-tax avoidance directive, which include limiting the exemption to the banking sector and requiring withdrawal of the exemption altogether after 31 December 2022.
The regulations will revoke the Hybrid and Other Mismatches (Financial Instrument: Exclusions) Regulations, SI 2019/1251, from 1 January 2020. Those regulations come into force on 29 November 2019 and have effect in relation to payments made on or after 1 January 2019.
The Hybrid and Other Mismatches (Financial Instruments: Excluded Instruments) Regulations, SI 2019/1345, introduce further requirements with effect from 1 January 2020 to preserve the exemption in respect of specific regulatory capital securities held by banks from the anti-avoidance rules on hybrids and other mismatches. The changes are needed to ensure the UK rules comply with minimum standards under the EU anti-tax avoidance directive, which include limiting the exemption to the banking sector and requiring withdrawal of the exemption altogether after 31 December 2022.
The regulations will revoke the Hybrid and Other Mismatches (Financial Instrument: Exclusions) Regulations, SI 2019/1251, from 1 January 2020. Those regulations come into force on 29 November 2019 and have effect in relation to payments made on or after 1 January 2019.
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