In Practice
163
Go to page
of
17
Preparing for a new UK securitisation framework
In this In Practice article the authors consider how buy- and sell-side parties to securitisation transactions can get ready to comply with the UK’s new securitisation framework.
18 March 2024Ripping up the rulebook: financing the energy transition
The authors set out some of the challenges faced by both lenders and equity investors when deploying capital towards energy transition projects at scale. Such challenges include the volume of capital expenditure required, novel technology risk, untested markets and the participation of diverse stakeholders with a range of different sectoral experience. The authors then draw on their firm’s experience to demonstrate pioneering approaches taken by lenders and investors to mitigate risk and establish bankable project structures.
18 March 2024International financing structures: increased focus on withholding tax
The ability to obtain withholding tax relief on interest payments is crucial in many international financing structures. For borrowers, without treaty relief, the cost of borrowing from a non-domestic lender increases significantly; in the absence of relief, domestic withholding tax is likely to apply, so the borrower must increase the payment due to the lender, under a so-called gross up clause. This is not entirely one-way; a lender based in a jurisdiction without access to a network of favourable tax treaties is likely to find it too difficult to lend money to foreign borrowers at similar returns to those lenders with access to a wide treaty network. These issues arise not only for third party lenders, but also where a group wishes to finance its international operations. In either case, the parties involved will want to prevent any withholding tax leakage.
18 March 2024
Go to page
of
17
