When thinking of structuring aircraft leasing deals, which
jurisdictions spring to mind? You might think Ireland. After all,
it's one of the most common places to hold SPVs. The chances
are Sweden wouldn't be at the forefront of your thoughts. So,
it may be surprising to discover that Sweden has become a hotspot
for aircraft lease-in and lease-out (LILO) SPVs. Sweden isn't a
traditional aviation hub, yet the Nordic country does hold some
strong connections with Argentina and Bolivia.
Sweden is a signatory of many international conventions,
including Geneva, Montreal and Cape Town. It's also part of the
OECD BEPS Multilateral Instrument and the OECD Model Tax Convention
on Income and Capital. The latter convention is a base of Swedish
double tax treaties.