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ARTICLE · 20 JULY 2013

Irish SPVs in Structured Finance and Fund Transactions

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Ireland has increasingly become the jurisdiction of choice in Europe for establishing special purpose vehicles ("SPVs") to conduct structured finance or fund transactions.

IrelandTax
Nollaig Murphy
Nollaig Murphy
Andrew Quinn
Andrew Quinn
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Advantages of using an Irish SPV
 Ireland has increasingly become the jurisdiction of choice in Europe for establishing special purpose vehicles ("SPVs") to conduct structured finance or fund transactions.  A significant factor in Ireland's attractiveness is the continued support of the Irish government and tax authorities and successive legislative changes to facilitate this business. Examples of this proactive policy are the 2010 and 2011 updates to Ireland's tax codes designed to facilitate and ensure certainty of treatment for SPVs to hold commodities, plant and machinery and carry out Shari'a compliant arrangements.

Tax Benefits
Effectively corporation tax neutral vehicle.  While SPVs within the scope of Section 110 of the Irish Taxes Consolidation Act 1997 ("Section 110") are subject to Irish corporation tax in the normal course, due to the favourable rules regarding deductibility of expenditure, including interest, it is generally possible to structure a

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