Davis Polk advised The Royal Bank of Scotland Group plc, a public limited company incorporated under the laws of Scotland, in connection with its SEC-registered shelf takedown of $1.5 billion aggregate principal amount of 6.000% reset perpetual subordinated contingent convertible additional tier 1 capital notes.

RBSG is the holding company of a large banking and financial services group. Headquartered in Edinburgh, RBSG operates in the United Kingdom and internationally through a network of branches, local banks and non-bank subsidiaries. The banks in the group authorized in the United Kingdom include NatWest Markets Plc, National Westminster Bank Plc, Coutts & Co and Ulster Bank Limited. RBSG has a diversified customer base and provides a wide range of products and services to personal, commercial and large corporate and institutional customers.

The Davis Polk corporate team included partner Reuven B. Young, counsel Connie I. Milonakis and associate Tanu Sinha. The U.S. tax team included counsel Alon Gurfinkel and associate Summer Xia. Partner Jonathan Cooklin, counsel Dominic Foulkes and associate Freddie Schwier provided U.K. tax advice. Partner Gregory S. Rowland and associate Allison Gunther provided 1940 Act advice. Members of the Davis Polk team are based in the London and New York offices.