Securitisation Structuring

There are many possible forms of securitization, which on their own or also combined with the inclusion of other possible SPVs could result in a number of tax advantages, including the following:

  • Activities of a SCC can achieve tax neutrality and non-Maltese resident originators and investors can typically also achieve additional tax advantages;

  • Malta’s double taxation agreements permits additional advantages on the underlying assets, particularly when held through SPVs;

  • Activities which are core and essential to the management of securitization are not subject to VAT.


The following is a possible multi-structure, involving:


  • 1 public company (SCC Plc), held by shareholders;

  • Receiving 4 transactions from originators, 3 of which through SPVs;

  • SCC Plc will issue 4 Cells;

  • 2 of which Cells have issued listed instruments on a stock-exchange; and

  • 2 of which Cells have made private placement investments, with 1 of them having a credit enhancement.

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