The Autumn Budget and Finance Bill 2018 contain some welcome developments for banks (for once). Nevertheless, the City continues to face challenges in 2018 in applying the complex legislation from 2017 on interest restriction. (The global differences in interest restriction rules are proving a big headache for multinationals.) HMRC’s final guidance on the penalties for enablers regime contains a revised section on the interaction with the code of practice on taxation for banks. Final hybrids guidance is added to HMRC’s International Manual but further tweaks to the legislation will be made. The new regime for the taxation of insurance linked securities begins.
