HYBRIDS

Matthew Rowbotham (Lewis Silkin) examines the Government’s consultation on double taxation for UK individuals in US LLCs and finds much to welcome, as well as some important issues still to resolve.

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.

Rhiannon Kinghall Were

Lucy Urwin

Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) report.

Zoe Andrews

Mike Lane

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Zoe Andrews

Mike Lane

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Gavin Orpwood Louise Keegan Hannah McKenzie

Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.

Helen Buchanan

John Tolman

Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine what is effectively the pilot episode for an upcoming courtroom drama.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.

Tim Sarson

Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.

Zoe Andrews

Mike Lane

Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime.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...

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