UK insurers ‘in limbo’ as HMRC reviews tax break for perpetual debt

HMRC building

UK insurers face constraints on their ability to issue perpetual debt instruments under a proposal to redefine their tax status.

Insurers and banks both issue perpetual debt to satisfy regulatory capital requirements. However, Her Majesty's Revenue and Customs (HMRC) has questioned whether such instruments should be legally defined as ‘loan relationships' (debt) when they do not have a fixed maturity date and only grant the holder a right to repayment on liquidation of the issuer. HMRC believes