HMRC updates CFM manual for hybrid capital instruments

HMRC has added new guidance to its corporate finance manual (CFM) covering the new hybrid capital instruments rules for regulatory capital issued by banks and insurers from 1 January 2019. The new sections are:

• CFM35175: Loan relationships: connected companies: hybrid capital instrument: tax rules - eliminating tax mismatches;
• CFM37800: Loan relationships: hybrid capital instruments: contents;
• CFM37810: Loan relationships: hybrid capital instruments: overview;
• CFM37820: Loan relationships: hybrid capital instruments: glossary;
• CFM37830: Loan relationships: hybrid capital instruments: what is hybrid capital?;
• CFM37840: Loan relationships: hybrid capital instruments: definition of hybrid capital instrument: definition of hybrid capital instrument for tax purposes;
• CFM37850: Loan relationships: hybrid capital instruments: tax provisions;
• CFM37860: Loan relationships: hybrid capital instruments: transitional provisions;
• CFM37870: Loan relationships: hybrid capital instruments: tax rules - interaction with other rules; and
• CFM37890 - Loan relationships: hybrid capital instruments: tax rules - RCS Regulations - 1 January 2014 to 31 December 2015.

See bit.ly/2lZxe7c.