SCHEDULE 20Taxation of hybrid capital instruments
PART 2Corporation tax, income tax and capital gains tax
Commencement for purposes of income tax and CGT
16
(1)
The provision made by paragraphs 1 to 4 has effect for the purposes of income tax in relation to payments made on or after 1 January 2019.
(2)
But the revocations made by paragraph 1—
(a)
do not affect the application of regulation 6 or 9 of the Taxation of Regulatory Capital Securities Regulations 2013 in relation to payments made before the day on which this Act is passed, and
(b)
do not, in the case of a transitional qualifying instrument, apply to payments made before 1 January 2024 in any case where regulation 6 or 9 of those Regulations would have applied but for the provision made by paragraph 1.
17
The revocations made by paragraph 1 have effect for the purposes of capital gains tax in relation to disposals made on or after 1 January 2019.
18
In so far as it relates to the definition of “corporate bond” in section 117(1) of TCGA 1992, the amendment made by paragraph 6 has effect in relation to disposals made on or after 1 January 2019.