The Autumn Budget and Finance Bill 2018 contain some welcome developments for banks (for once). Nevertheless, the City continues to face challenges in 2018 in applying the complex legislation from 2017 on interest restriction (the global differences in interest restriction rules proving a big headache for multinationals). HMRC’s final guidance on the penalties for enablers regime contains a revised section on the interaction with the Code. Final hybrids guidance is added to HMRC’s International Manual but further tweaks to the legislation will be made. The new regime for the taxation of insurance linked securities begins.
This article was first published in the 19 January 2018 edition of Tax Journal.
