Overview
James Ross assessed potential tax changes on company distributions in the 2015 UK Budget Autumn Statement, noting that “quite how that would work is anyone’s guess, particularly for minority shareholders who have no way of analysing the character of the receipts out of which distributions are made.” Tom Scott added that if the government introduces legislation to address the tax treatment of hybrid mismatch arrangements, “the hunt will be on next year for effective replacement debt structures – maybe moving towards tax rate arbitrage rather than a hybrid outcome.” Read the full article.