In a recent transaction, a local shareholder consortium was required to exchange its shareholding in a local company for shares in a Canadian listed company. The challenges were significant, not least of which were overcoming a loop structure to obtain exchange control approval and potentially vast Capital Gains Tax (CGT) on the disposal.
Working with one of the local banks, our team devised a sequence of events which utilised the bank's swap capacity to acquire the offshore shares as well as a series of bridging loans. The result was a massive saving in CGT and a positive net cash flow for the local consortium.