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Tax treatment of instruments designed to be compliant with the Capital Requirements Directive 4

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Charles Yorke

Partner

London

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Tilakapala Vimal
Vimal Tilakapala

Consultant

London

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06 July 2012

HM Revenue & Customs (HMRC) have published a paper setting out their views on the tax treatment under current law of instruments designed to be compliant with the Capital Requirements Directive (CRD) 4.  The paper concerns current law only, and not any changes that might be made in future in response to CRD 4.  The paper also considers the treatment of perpetual instruments more generally.  This bulletin answers some key questions that arise.

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