n Without Prejudice - Security SPVs and tax neutrality : tax

Volume 14, Issue 11
  • ISSN : 1681-178X



Despite the bad press that special purpose vehicles (SPVs) received during the Enron scandal, they are still an everyday feature of many financial structures. They are commonly used in project finance transactions and in respect of employee incentive schemes, and normally serve a specific business purpose: they are generally created to be independent, bankruptcy remote vehicles and allow the financiers in syndicated loan transactions to share the proceeds of the security provided by the borrower. For example, a typical greenfields renewable energy project might have several financiers and "Security SPVs" would typically be an integral part of the financing arrangements required by the financiers of such a project.

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