Example 1: Securitisation using offshore Special Purpose Vehicle (SPV) funded by listed bonds

As part of a securitisation arrangement, an SPV is established in Ireland. It purchases UK interest bearing receivables, funding itself with listed bonds which, if issued by a UK resident company, would qualify for exemption from withholding tax by virtue of the quoted Eurobond exemption at ITA07/S882 (formerly ICTA88/S349(3)(c)). The UK source interest is paid to the SPV which, in turn, pays interest to the bondholders who are resident in a variety of different countries.

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