Equity capital markets transactions take a number of forms, from IPOs to rights issues, open offers and placings of various types. Tax will be an important consideration, from the point of view of the share-issuing company, its shareholders and any acquirers of shares, as well as any financial intermediary involved. It will be important to minimise any transaction taxes (such as stamp duty) and, in some transactions, potential chargeable gains tax liabilities for shareholders (hence the significance of ‘reorganisation’ treatment). Any pre-transaction restructuring will also need to be carefully planned to minimise attendant tax costs.
