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The government has published details of amendments to new rules on the taxation of hybrid capital instruments, which are designed to ensure they work as intended for instruments with a takeover or change of control clause.
Hybrid capital instruments are a form of debt with some features of equity. This can lead to uncertainty as to whether the payments under the hybrid instrument should be taxed as interest (which is typically deductible) or as distributions (which are not).
Read more at the Accountancy Daily.