HMRC has launched a consultation on draft regulations that will remove a sunset clause from the hybrid and other mismatches rules so that an exemption for certain hybrid instruments issued by banks continues to apply from 1 January 2023.
The Hybrid and Other Mismatches rules at Part 6A of the Taxation (International and Other Provisions) Act 2010 contain an exemption for certain hybrid instruments issued by banks. This exemption will otherwise fall away after 31 December 2022 due to a ‘sunset clause’ in SI 2019/1345. These new draft regulations would remove the sunset clause, preserving the exemption. The consultation closes on 30 June 2022.
HMRC has launched a consultation on draft regulations that will remove a sunset clause from the hybrid and other mismatches rules so that an exemption for certain hybrid instruments issued by banks continues to apply from 1 January 2023.
The Hybrid and Other Mismatches rules at Part 6A of the Taxation (International and Other Provisions) Act 2010 contain an exemption for certain hybrid instruments issued by banks. This exemption will otherwise fall away after 31 December 2022 due to a ‘sunset clause’ in SI 2019/1345. These new draft regulations would remove the sunset clause, preserving the exemption. The consultation closes on 30 June 2022.
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