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Structuring7 min read

SPV structures for single-asset deals

Why a special-purpose vehicle is the standard way to hold one deal or co-investment, how a cross-border holding stack typically looks, and the governance, economics and compliance questions to settle before you subscribe.

A special-purpose vehicle (SPV) is a company or partnership formed to do exactly one thing — typically to hold a single asset or a single co-investment. For exposure to a Zimbabwean opportunity, an SPV lets a group of investors pool capital, ring-fence the risk of that one deal, and present a single, clean counterparty to the operating business on the ground.

Why an SPV at all?

  • Risk ring-fencing: the liabilities of the deal sit in the SPV, not on each investor's wider balance sheet.
  • A single cap table: many co-investors hold the asset through one entity, which simplifies governance and exit.
  • Clean transferability: an investor exits by transferring SPV shares rather than re-papering the underlying asset.
  • Jurisdiction fit: the holding layer can sit where investors are comfortable contracting, while the asset stays local.
  • Aligned economics: fees, carry and distributions are defined once, at the SPV level, for all co-investors.

A typical cross-border stack

For deals on this desk the common shape is three tiers: a US holding entity (often a Delaware LP or LLC) that international investors subscribe into; where needed, a feeder for non-US investors; and a Zimbabwean (Pvt) Ltd that actually holds the licence, concession or operating asset. The US layer is where the investment documents live and disputes are resolved; the Zimbabwean layer is where ZIDA registration and RBZ exchange-control compliance bite. A co-investment SPV usually sits in the holding layer.

The right structure is fact-specific. Tax residence, treaty access, exchange control and the nature of the underlying asset all change the answer. Treat the shape above as a starting point to discuss with counsel, not a template to copy. This is general information, not advice.

What to settle before you subscribe

  • Economics: total raise, your commitment, your percentage, and the fee and carry the lead charges.
  • Drawdown: paid in full on completion, or drawn in tranches on notice — and the consequences of a default.
  • Governance: who controls the SPV, what information you receive, and which decisions are reserved.
  • Exit: pre-emption, drag-along and tag-along, and how a sale of the asset flows back to SPV holders.
  • Compliance: KYC/AML, investor eligibility, and how capital gets in and profits get out under RBZ rules.

The paper trail

An SPV co-investment usually moves through the same documents: a co-investment term sheet records the slice and headline terms; the SPV's constitution and a shareholders' agreement govern the relationship between holders; and an SPV subscription brings you in for shares. The co-investment term sheet and the SPV subscription summary are available as fillable templates here.

This guide is general information only and does not constitute investment, legal or tax advice, nor an offer of any security or interest in any vehicle. Rules and market conditions vary and change over time. Obtain your own independent advice before taking any action.