Citation, commencement and effect
1.—(1) These Regulations may be cited as the Taxation of Regulatory Capital Securities (Amendment) Regulations 2015 and come into force on 1st January 2016.
(2) These Regulations have effect—
(a)for the purposes of income tax, for payments made on or after 1st January 2016;
(b)for the purposes of corporation tax, for accounting periods beginning on or after that date (this is subject to paragraph (3) and regulation 3);
(c)for the purposes of capital gains tax, in relation to disposals made on or after that date;
(d)for the purposes of stamp duty, in relation to instruments executed on or after that date;
(e)for the purposes of stamp duty reserve tax—
(i)in the case of agreements to transfer securities which are not conditional, in relation to agreements made on or after that date, and
(ii)in the case of agreements to transfer securities which are conditional, in relation to agreements where the condition is satisfied on or after that date.
(3) In relation to instruments issued by a company in an accounting period beginning before 1st January 2016—
(a)amendments made by regulation 2(3)(a)(i), (c) and (d) (fair value accounting) do not apply, and
(b)references to fair value accounting in the Taxation of Regulatory Capital Securities Regulations 2013(1) (“the principal Regulations”) are to be read without regard to the amendment of section 313(5) of CTA 2009 made by paragraph 7(7) of Schedule 7 to F(No 2)A 2015(2).