Introduction Background
5.Once the Capital Requirements Directive IV (CRD IV) is in force, bank’s Tier Two capital must have more loss absorbing features than previously. Tier Two capital will also have to count as Tier Two throughout the life of the instrument (including after CRD IV is in force). Both these requirements have caused tax issues in relation to the CT distributions and group relief rules which these provisions seek to address.
6.This section was announced and came into force on 26 October 2012.