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Hybrid Financing

Sara Luder of Slaughter and May looks at the new tax arbitrage rules in Finance (No. 2) Act 2005
It is relatively easy to tell the difference between debt and equity isn't it? Equity is riskier and carries no certainty of a return but the holder has a say in the running of the business and the returns are potentially uncapped. By contrast a lender has a right be repaid his investment in full together with an agreed profit but has no involvement in the running of the business.
But life is not that straightforward. Holders of non-voting redeemable fixed rate preference shares expect to receive a fixed return from their investment and their money back but the shares are still equity. Holders of...

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