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Tax and the City briefing for November 2014

Speed read

New rules will prevent hybrid mismatches, but with exclusions for hybrid regulatory capital. Regulations limit the scope of the ‘promoters’ definition in the rules for high-risk promoters. The First-tier Tribunal is not persuaded that euro conversion clauses give rise to non-QCB status. The European Commission makes an initial finding of unlawful state aid as a result of Irish tax rulings; while the Irish government announces the demise of the ‘double Irish’. A new online service is launched by HMRC for financial institutions registering and reporting under FATCA

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