Hybrid Capital Instruments: 2019 Tax Changes in the United Kingdom and the Netherlands

This article discusses changes relating to the taxation of contingent capital (CoCos, hybrids, additional Tier 1 capital, innovative capital, Basel I, II and III) in the United Kingdom and the Netherlands, the question of debt or equity, the new and old regimes in the United Kingdom, the background to the change in the Netherlands and tax policy and potential effects.