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The base erosion tax requires an annual calculation. Tax equity traders is not going to know till the end of every year whether they will have to spend back again tax credits on which they ended up counting that year.
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These can be undertaken in a variety of sorts. If the EBRD requires an fairness stake, it expects an correct return on its expenditure and can only have a minority situation.
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Most tax equity buyers are uninterested in the existing 50% depreciation bonus. They would prefer to unfold their scarce tax potential around a lot more projects.
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After the capital account is fatigued, the remaining depreciation shifts back again to the developer and could drag tax credits with it.