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

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