With the rapid development of financial transactions and innovative financial products in China, hybrid investments, which normally have a dual nature of equity and debt investments, have become a popular investment vehicle used by many companies, such as trust companies, in recent years. Examples of such hybrid investments include preferred stocks and convertible bonds from which periodic fixed interests or profits would be derived.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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