When the qualifying private placement (QPP) exemption was introduced in 2015, it was hoped it would open up the UK private debt market, but its use remains relatively limited in practice. We explore some potential reasons why, despite the private capital market now being bigger than it was, QPP has not proven to be the easy-fix it was hoped it would be. That said, QPP has proven its utility as a ‘bolt-on’ relief in circumstances where treaties or timings would (pre-QPP) have prevented an interest payment from being made free from withholding.
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When the qualifying private placement (QPP) exemption was introduced in 2015, it was hoped it would open up the UK private debt market, but its use remains relatively limited in practice. We explore some potential reasons why, despite the private capital market now being bigger than it was, QPP has not proven to be the easy-fix it was hoped it would be. That said, QPP has proven its utility as a ‘bolt-on’ relief in circumstances where treaties or timings would (pre-QPP) have prevented an interest payment from being made free from withholding.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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