HM Revenue and Customs (HMRC) has published a draft of the Taxation of
Regulatory Capital Securities Regulations 2013. The Regulations set out
provisions in relation to the taxation of Additional Tier 1 and Tier 2
regulatory capital securities that financial institutions need to issue to meet
their regulatory requirements. The Regulations are intended to ensure
that these securities are taxed as loan relationships and the coupons are taxed
Comments are due by 15 September 2013.