Draft regulations: amendment to the Hybrid and Other Mismatches rules to retain an exemption for certain hybrid instruments issued by banks
This technical consultation seeks views on draft regulations that will remove a sunset clause from the Hybrid and Other Mismatches rules so that an exemption for certain hybrid instruments issued by banks continues to apply from 1 January 2023.
Detail
The Hybrid and Other Mismatches rules at Part 6A of the Taxation (International and Other Provisions) Act 2010 contain an exemption for certain hybrid instruments issued by banks.
This exemption will fall away after 31 December 2022 by virtue of a sunset clause, which was required by an EU directive.
These regulations will remove the sunset clause and allow the exemption to continue to apply from 1 January 2023.
Before submitting your response, you can read these publications:
- (draft) The Hybrid and Other Mismatches (Financial Instruments: Excluded Instruments) (Amendment) Regulations 2022
- (draft) explanatory memorandum
- (draft) tax information and impact note
Documents