Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 10 SEPTEMBER 2025

Typical Fund Structures - Section 110 Companies

Arthur Cox
Explore more from Arthur Cox

A Section 110 company can take a deduction for interest on profit participating notes ("PPNs") provided it satisfies 4 rules...

IrelandCorporate/Commercial Law
Arthur Cox
Arthur Cox
Author LinkedIn connections

1676052 a.jpg

TAX

A Section 110 company can take a deduction for interest on profit participating notes ("PPNs") provided it satisfies 4 rules:

Section 110 Rules – a deduction should be available where:

  • PPN is held by a resident of an EU/Treaty country and that noteholder is subject to tax; or
  • PPN is listed and noteholder is not a "specified person". A "specified person" includes a person (i) controlling the p 110 company, including by holding 20%+ PPNs and having "significant influence"; or (ii) providing 75% of the assets of the p 110 company. A person will be regarded as having "significant influence" if it has the ability to participate in the financial and operating decisions of the p 110 company (eg. where the PPN holder is the manager or an entity related to the manager or appoints directors to the board, etc).

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

A Deep Dive Into The Regulation Of Artificial Intelligence Bill 2026

The Irish Government has published the Regulation of Artificial Intelligence Bill 2026, establishing a comprehensive framework for supervising and enforcing the EU AI Act in Ireland. This legislation creates the AI Office of Ireland as an independent statutory body to coordinate AI regulation, introduces a distributed oversight model involving multiple sectoral authorities, and provides detailed procedures for adjudication and administrative sanctions. The Bill addresses critical questions about how Ireland
IrelandCorporate/Commercial Law
Matheson
Matheson
Article

AMLD6 And Beneficial Ownership Central Registers: New Access Rules In Ireland

Ireland has introduced significant amendments to its beneficial ownership registers in 2026, implementing the Sixth Anti-Money Laundering Directive (AMLD6) framework. These reforms fundamentally restructure access rights to the Central Register of Beneficial Ownership of Trusts and Corporate Entities, moving away from unrestricted public access toward a tiered system that balances transparency with privacy rights while maintaining accessibility for legitimate anti-money laundering purposes.
IrelandCorporate/Commercial Law
Dillon Eustace
Dillon Eustace
Article

CSRD Simplification Takes Shape: Revised ESRS And Voluntary Standard Published

The European Union has published revised sustainability reporting standards and introduced a voluntary framework that fundamentally changes how companies approach CSRD compliance. These reforms reduce reporting complexity through fewer datapoints and introduce value chain caps that limit information requests from smaller businesses. Understanding these changes is critical for both mandatory reporters and voluntary participants as implementation deadlines approach in 2026 and 2027.
IrelandCorporate/Commercial Law
Arthur Cox
Arthur Cox
Article

Corporate Update October 2026 - Company Law, Compliance & Governance

This legislative update examines Ireland's Autumn 2026 legislative agenda, including reforms to director address disclosure and cooperative societies law, while analyzing key governance trends from the UK proxy season and the European Commission's corporate law harmonization priorities. The analysis explores shareholder activism, board diversity expectations, and the EU's ambitious "EU Inc." framework aimed at creating unified company law across Member States.
IrelandCorporate/Commercial Law
Arthur Cox
Arthur Cox
Article

Charities (Amendment) Bill: What It Means For Northern Ireland Operations

The Northern Ireland Assembly is advancing the Charities (Amendment) Bill, which introduces significant regulatory changes for charities operating in the jurisdiction. The legislation grants the Charity Commission for Northern Ireland expanded enforcement powers, overhauls accounting and reporting frameworks based on charity size, and clarifies the status of cross-border charitable organizations.
IrelandCorporate/Commercial Law
Withers LLP
Withers LLP
Article

EU’s Revised Sustainability Reporting And Due Diligence Rules Agreed

After months of intense negotiations, the European Parliament (the “Parliament”) and the Council of the European Union (the “Council”) have agreed new laws that substantially revise and simplify the EU’s corporate sustainability rulebook. Final approval of the package has been obtained and the amended “omnibus” directive (Directive (EU) 2026/470) was published in the Official Journal of the European Union on 26 February 2026.
European UnionCorporate/Commercial Law
Matheson
Matheson