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“If you build it, they will come” – An increasingly diverse and complex energy market brings with it ... Tax complexity paper


This paper covers:

  • UK substantial shareholding exemption
  • large-scale generation shortfall charges
  • proxy revenue swaps
  • impact of the stapled structure reforms on the renewable energy industry.




Author profiles

Richard Buchanan CTA
Richard is a partner at EY and specialises in the tax aspects of major transactions, including mergers and acquisitions, infrastructure and property projects. He regularly provides advice through the life cycle of the transaction, including funding, structuring, due diligence, documentation negotiation and post-acquisition integration. Richard’s role in infrastructure transactions can vary from advising bidding consortiums, representing lending syndicates, advising vendors and representing equity in a consortium. - Current at 29 May 2019
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Aaron Khoury


This was presented at 2019 National Infrastructure Conference .

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Infrastructure market and trends/outlook

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ATO keynote speaker address - Current issues in the infrastructure sector

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US tax reforms and BEPS measures

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Trends in tax litigation

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Hybrid mismatches & infrastructure

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