[INTM332080] INTM332080 – Double Taxation applications and claims: Indofood: Examples of application
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.