Pillar Two and structured finance – What impact is the new global minimum rate of tax having on structured finance transactions?

The Allen & Overy Podcast archive - A podcast by Allen & Overy

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In this podcast, our tax experts look into the implications of Pillar Two, the OECD/G20’s initiative to introduce a global minimum tax, for structured finance transactions. Tax partners Chris Harrison, Esther Lemmon and Charles Yorke speak to tax knowledge counsel Brin Rajathurai about various topics including: A recap of the global minimum tax – what is Pillar Two and how does it work? The tax consequences of the new rules in the context of structured finance transactions and the potential commercial repercussions The significance of consolidation for Pillar Two purposes and unexpected grouping of orphan vehicles How the UK and other jurisdictions are addressing some of the potential issues for structured finance transactions