Tax can easily scupper a structured finance transaction. If the standard SPV issuer in that transaction incurs significant amounts of corporate income, value added or other taxes, the transaction may well be unviable. The role of the tax adviser in this area, therefore, is to minimise those taxes wherever possible. Thankfully, there are established paths, involving particular jurisdictions and taxation regimes, for doing so. However, the tax neutrality of this type of transaction should never be assumed. As with any other transaction, moreover, it is subject to change of law risk.
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Tax can easily scupper a structured finance transaction. If the standard SPV issuer in that transaction incurs significant amounts of corporate income, value added or other taxes, the transaction may well be unviable. The role of the tax adviser in this area, therefore, is to minimise those taxes wherever possible. Thankfully, there are established paths, involving particular jurisdictions and taxation regimes, for doing so. However, the tax neutrality of this type of transaction should never be assumed. As with any other transaction, moreover, it is subject to change of law risk.
If you are not a subscriber, subscribe now to read this content.
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