CORPORATE TAXES

Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime.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

This years Act makes the following changes to the capital allowances regime:The annual investment allowance (AIA) limit is increased to 1m between 1 January 2019 and 31 December 2020.Enhanced capital allowances (ECA) are removed from...

FA 2019 contains two notable changes to UK taxation of controlled foreign companies (CFCs), both of which take effect from 1 January 2019.The current UK CFC rules were included in FA 2012, following a significant re-write of older provisions. The...

Schedule 11 makes a number of changes to the corporate interest restriction legislation that is contained in TIOPA 2010 Part 10 and which took effect from 1 April 2017. Most of the changes made by Sch 11 have been made to ensure that the legislation...

In 2017, the UK implemented a detailed set of hybrid mismatch rules to combat cross-border tax advantages arising from hybridity for example, the differing tax treatments of entities, transactions or instruments. The...

This month’s tax developments that matter for the City, by Mike Lane and Zoe Andrews (Slaughter and May).

The Commission neatly shifts its position on the UK’s CFC rules, writes Paul Davison (Freshfields Bruckhaus Deringer).

This report, which sets out the key tax changes taking effect from April, was prepared by Deloitte’s Mark Groom (partner), Patricia Mock (tax director), Dan Nazarian (associate director) and Donna Huggard (associate director).

Nicola Saccardo (Maisto e Associati) discusses potential direct tax consequences of Brexit for multinational groups.