The Taxation of Hybrid Capital Instruments (Amendment of Section 475C of the Corporation Tax Act 2009) Regulations 2019
These Regulations amend section 475C of the Corporation Tax Act 2009 (c. 4) to ensure that the rules relating to hybrid capital instruments, introduced in Schedule 20 to the Finance Act 2019 (c. 1), work as intended. Specifically, these amendments ensure that where a loan relationship includes a takeover or change of control provision which could result in a conversion into ordinary share capital of a company which (together with its associates) controls the debtor, that provision will not cause the loan relationship to fall outside of the rules.