SCHEDULES

SCHEDULE 20Taxation of hybrid capital instruments

PART 2Corporation tax, income tax and capital gains tax

Consequential amendments

9(1)The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2004 (S.I. 2004/3256) are amended in accordance with this paragraph.

(2)In regulation 2(1) (interpretation)—

(a)after the definition of “fair value profit or loss” insert—

  • hybrid capital instrument” has the meaning given by section 475C of CTA 2009;, and

(b)omit the definition of “regulatory capital security”.

(3)In regulation 3 (exchange gains or losses arising from liabilities or assets hedging shares etc), in paragraph (5)(c), for “a regulatory capital security” substitute “a hybrid capital instrument”.

(4)In regulation 4 (exchange gains or losses arising from derivative contracts hedging shares etc), in paragraph (4A)(c), for “a regulatory capital security” substitute “a hybrid capital instrument”.