Kunal Vyas and Kevin Cummings review the UK tax regime, and suggest that the often knee-jerk reaction of many originators and market participants to go offshore is, in many cases, unnecessary.
Legal and regulatory markets being equal deal sponsor preference has tended towards the use of low-tax vehicles in Ireland Luxembourg Jersey or Cayman so as to maximise post-tax returns for investors. An onshore structure may however be appropriate particularly where the debt pool is UK-sited and active management is envisaged (such as dealing with restructuring and workout scenarios) so as to avoid the need for the complex...
