ARTICLE · 03 JULY 2025

CLOs

Arthur Cox

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Arthur Cox is a principal Irish advisor in the European CLO market. From advising the pre-eminent Irish-domiciled CLO managers to developing bespoke risk retention structures in Ireland using Section 110 vehicles...

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Brendan Kennedy

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Arthur Cox is a principal Irish advisor in the European CLO market. From advising the pre-eminent Irish-domiciled CLO managers to developing bespoke risk retention structures in Ireland using Section 110 vehicles, we are at the forefront of the key regulatory and structuring issues facing the European CLO market and also helped establish the 'originator structure' first used in Europe by Blackstone on the Phoenix Park transaction.

Ireland increasingly dominates the EU CLO market in large part due to its robust legal framework and finely tuned tax system.

Favourable tax laws allow the structures to be, in most cases, tax neutral (with a minimal annual profit or 'spread' required at the SPV level) and a 'quoted eurobond' exemption allows interest on securities to be paid gross. A minimal share capital requirement of €1 in most cases makes incorporating an Irish SPV an easy process. Additionally, Euronext Dublin is a market leader in the listing of debt

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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.

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