INTRODUCTION
The Finance Act, 1999 introduced changes to the taxation regime governing the securitisation of assets through an Irish special purpose company ("SPV").
The changes effectively expand the options available in Ireland in relation to such securitisations. Formerly, the rules only applied to SPVs established in Dublin's International Financial Services Centre ("IFSC") and certain SPVs dealing with Irish mortgage receivables.
SECURITISATION - THE PROCESS
Asset securitisation has become one of the most important financing vehicles worldwide, enabling companies to tap international securities markets and raise funds at lower cost than traditional financing methods. Broadly, the process is one whereby pools of individual assets are transferred to an SPV. The SPV typically funds its purchase of the assets by issuing bonds to investors. The bonds are collatoralised by the assets held in the SPV and by the cash flows arising from it. This cash flow represents the primary
