Exposure draft regulations addressing the treatment of certain term subordinated notes

This consultation process has now been completed.
Consultation Type
Exposure Draft

Key Documents

The exposure draft regulation will facilitate certain term subordinated notes being treated as debt interests for the purposes of the debt/equity tax rules. The regulation aims to ensure that certain clauses relating to solvency and capital adequacy will not preclude such notes from being debt interests. The clauses are commonly found in Lower Tier 2 term subordinated notes issued by authorised deposit-taking institutions. However, the regulation will apply to all issuers.

This consultation forms part of the Taxation of Financial Arrangements (TOFA) initiative.


No submissions are currently available.