The key tax issues that arise on a bond issue usually relate to: withholding tax; stamp taxes; the tax treatment of the bond issuer and bondholders; VAT; Foreign Account Tax Compliance Act (FATCA); and the proposed financial transactions tax. This article gives further guidance on the tax issues which should be reflected in the documentation, including the mandate letter, underwriting agreement, offering document, fiscal agency agreement, trust deed, global note and legal opinion.
