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:

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• 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.