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ARTICLE · 07 JANUARY 2016

Ireland Confirms AT1 Instruments Treated As Debt

Ireland's Finance Bill 2015 (the Bill) was published on October 22 2015 and it contains new (previously unannounced) provisions on the Irish tax treatment of Additional Tier 1 (AT1) instruments.

IrelandFinance and Banking

Ireland's Finance Bill 2015 (the Bill) was published on October 22 2015 and it contains new (previously unannounced) provisions on the Irish tax treatment of Additional Tier 1 (AT1) instruments. The Bill confirms that AT1 instruments qualifying as such under the Capital Requirements Regulations will be regarded as debt instruments.

What are AT1 instruments?

In general terms, AT1 instruments are a form of loss-absorbing capital issued by banks (also known as contingent convertible capital). They are similar in nature to debt instruments but convert to equity or can be written down if bank regulatory capital falls below a specified level.

Change in Revenue policy on deductibility

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