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Clifford Chance

Clifford Chance
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Tax treatment of Additional Tier 1, Restricted Tier 1 & corporate hybrids

12 July 2022

The summary table is intended to provide an overview of the tax treatment of Additional Tier 1 (AT1) issued by banks, Restricted Tier 1 (RT1) issued by insurers and corporate hybrids by corporates in certain European jurisdictions.

In this technical briefing we discuss the classification, corporate tax deductibility, withholding tax treatment and other important topics of AT1, RT1 and corporate hybrid instruments.

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