Bank Capital Requirements: UK Tax Treatment of New Regulatory Capital Instruments Following Basel III

Sullivan & Cromwell LLP - July 1, 2011

On June 22, 2011, HM Revenue & Customs published a discussion paper on the UK tax treatment of securities which UK financial institutions may issue to strengthen their regulatory capital base in compliance with Basel III. The paper had first been issued in May as a basis for discussion at a meeting held on May 18 of a working group made up of HMRC officials and industry experts. HMRC have also published the minutes of the meeting.