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Home
Hybrids
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Hybrids
HYBRIDS
UK loan structures: changes to the anti-hybrid rules
Matthew Mortimer
Kirsten Hunt
Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.
Legislation day: what you need to know
Lucy Urwin
Rhiannon Kinghall Were
Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) report.
Tax and the City review for May 2021
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Tax and the City review for February 2021
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
International business operating models: the tax issues
Hannah McKenzie
Gavin Orpwood
Louise Keegan
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
Tax and the City review for May 2020
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
International review for September 2019
Tim Sarson
Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.
Tax and the City review for May 2019
Mike Lane
Zoe Andrews
Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime. An HCI is a loan relationship under which the debtor (but not the...
The new regime for hybrid capital instruments
Mike Lane
Mike Lane (Slaughter and May) explains how the new rules might work in practice.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
Reeves should ‘grasp the nettle’ on tax reform, says IFS
HMRC raise game on football clubs
Conservatives would scrap SDLT, says Badenoch
Tax treatment of cryptoasset exchange traded notes
Trusts & estates return: practical point
CASES
Read all
Mainpay Ltd v HMRC
Dialog Semiconductor Ltd v HMRC
Hippodrome Casino Ltd v HMRC
Other cases that caught our eye: 17 October 2025
GW Martin & Co Ltd and another v HMRC
IN BRIEF
Read all
Taking cover
More on s 455
HMRC’s technical note on RIFs
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
MOST READ
Read all
HMRC’s new NIC guidance on internationally mobile employees
Jumpman Gaming Ltd v HMRC
Isle of Wight NHS Trust v HMRC
GfC 13 and the filing position: nothing to see here?
Legislating against promoters of marketed tax avoidance scheme