SPV

Matthew Mortimer and Kitty Swanson (Mayer Brown) consider some important tax treatments that can apply to structured finance transactions.

Sofia Casselbrant-Multala and Dominic Stuttaford (Norton Rose Fulbright) examine the Court of Appeal decision in Rossendale that demonstrates the potential general application of the Ramsay approach, but clearly shows its limits as a means of countering avoidance.

Peter Jackson (Taylor Wessing) examines the tax issues surrounding a UK REIT group which wishes to purchase shares in a UK resident and a non-UK resident SPV.

Keith Gregory (NGM Tax Law) answers a query on how an EBT trustee wishing to provide loan finance in connection with a joint venture development company can avoid triggering a charge under the disguised remuneration rules

Jonathan Fletcher Rogers considers to what extent the Ramsay principle can be applied to tax avoidance schemes involving employee bonuses.