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An Irish Section 110 special purpose vehicle (SPV) or section 110 company is an Irish tax resident company, which qualifies under Section 110 of the Irish Taxes Consolidation Act 1997 (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties.
Tax secrecy. Unlike the Section 110 SPV, the L–QIAIFs are not required to file public accounts (this was how the Section 110 tax abuses were uncovered), but file confidential accounts with the Central Bank of Ireland, that are protected under the 1942 Central Bank Secrecy Act; [13] No need for Profit Participating Notes ("PPN"). Another ...
A Section 110 Special Purpose Vehicle ("SPV") is an Irish tax resident company, which qualifies under Section 110 of the 1997 Irish Taxes Consolidation Act ("TCA"), by virtue of restricting itself to only holding "qualifying assets", for a special tax regime that enables the SPV to attain full tax neutrality (i.e. the SPV pays no Irish ...
A special-purpose entity (SPE; or, in Europe and India, special-purpose vehicle/SPV; or, in some cases in each EU jurisdiction, FVC, financial vehicle corporation) is a legal entity (usually a limited company of some type or, sometimes, a limited partnership) created to fulfill narrow, specific or temporary objectives.
In February 2018, the Central Bank of Ireland, which regulates Section 110 SPVs, upgraded the little used tax-free L-QIAIF regime, which has stronger privacy from public scrutiny. [133] [178] In June 2018, U.S. distressed debt funds transferred €55 billion of Irish assets (or 25% of Irish GNI*), out of Section 110 SPVs and into L–QIAIFs ...
Structures such as the Section 110 SPV are being used to create more advanced artificial loan structures, which are harder to understand and prevent, for BEPS-type activities (including money laundering/regulatory avoidance purposes). There has been a material uplift in Section 110 SPVs by sanctioned Russian financial institutions.
The SPV is generally a limited liability company issued in either an offshore location (e.g. the Cayman Islands SPV) or an onshore location (e.g. Irish Section 110 SPV). [4] [5] The key considerations in deciding what 3rd party entities are used to "own" the orphaned SPV equity are driven by:
Revenue will calculate the tax payable for a person who files a return of income more than two months prior to the filing deadline. [ 62 ] Underpaid tax attracts an interest penalty charge of 0.0219% per day, [ 62 ] and underpayments may result in a surcharge, [ 63 ] prosecution, [ 64 ] or publication of their name in a defaulters' list.