Withholding tax issues on Facility Agreements: traps for the unwary
The basic position on withholding taxes in LMA facility agreements is often summarised by saying that the borrower only takes change of...
Jill is a partner in our tax practice, advising corporate groups, financial institutions and investment funds on a broad range of transactions.
Her work includes public and private M&A, equity and debt issuances, returns of capital, demergers, real estate investment and refinancings. She structures transactions to achieve the best possible outcome for clients, often where there are many competing considerations.
Jill has particular experience of transactions with substantive regulatory considerations. She has worked on insurance business transfers, acquisitions and reorganisations of asset-management businesses and financings of insurance groups. In these cases, she works closely with regulatory colleagues to ensure the transaction is successful from both a regulatory and tax perspective. Jill enjoys working through highly technical tax issues, but is keenly aware that tax is very rarely the key driver of commercial transactions.
Jill regularly works with international teams to address jurisdiction-specific issues, including in emerging markets.
The basic position on withholding taxes in LMA facility agreements is often summarised by saying that the borrower only takes change of...
The structuring and negotiation of management incentive plans (MIPs) is now a common and increasingly important aspect of European...
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