The qualifying private placement exemption: a sticking plaster solution?

The qualifying private placement exemption (QPP) was introduced by FA 2015 with effect from 1 January 2016. It was intended to remove some of the withholding tax (WHT) obstacles for the private placement market that was newly developing at the time. This was in response to a government commissioned report (the Breedon Review) published in March 2012 highlighting the constraints on bank lending following the financial crisis and the need for alternative sources of funding for business. Facilitating the ability of private investors to lend into the UK market outside of the listed bond market was seen as important in order to open up a new source of funding in particular for mid-sized borrowers. Given the purpose of the exemption simplicity was key. To qualify for QPP debt does...