There has been significant interest in whether SPAC listings, popular in the US, could be marketed on European exchanges. Transactions involving UK SPACs, target companies or investors present a multitude of tax issues. Parties need to consider whether the usual mix of shares and warrants that comprise the SPAC’s capital structure may lead to UK tax leakage. Once a target is identified, attention must turn to how the business combination can be undertaken in an effective and tax efficient manner, balancing the interests of the sponsors, investors and target shareholders with the overarching need to find a structure that meets the parties’ commercial objectives.
*This article first appeared in Tax Journal.