Ireland has become a favoured jurisdiction of choice in the EU for the establishment of special purpose vehicles (SPVs) that are used in securitisation and structured finance transactions.
One of the primary reasons for Ireland’s reputation in this area is the tax regime under Section 110 of the Taxes Consolidation Act 1997 (Section 110). Other reasons include:
- the range of SPV service providers that are based in Ireland.
- Ireland’s extensive network of double taxation treaties.
- Ireland is an open economy with an accessible and pro-business legislature that promotes and supports Ireland’s competitiveness in international capital markets.
This article explores some of the benefits of using Irish SPVs for securitisation and structured finance transactions.