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HYBRID-MISMATCHES


This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) report.
The UK hybrid rules impose double taxation as currently enacted, explain Nick Evans and Claudine Fox (Baker McKenzie). Changes will be made, but do they go far enough?
Will Smith and Lily Teh (White & Case) consider some of the major trends and tax issues relevant to the establishment and operation of credit funds. 
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
The exclusion from the hybrid mismatch rules for regulatory capital instruments has been narrowed to comply with ATAD. 

Jonathan Rosen (Akin Gump Strauss Hauer & Feld) considers the recent restrictions on corporate interest deductibility, and their impact on the UK’s attractiveness as a holding company jurisdiction.

Dominic Foulkes and Jonathan Cooklin (Davis Polk) consider some developments on the taxation of lending into UK acquisition finance structures.
 

Mike Lane and Zoe Andrews (Slaughter and May) take a look at recent developments affecting the City.

Daniel Head and Kashif Javed (KPMG) assess some of the practical challenges facing corporate groups.
 
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