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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.
Central Bank of Ireland ("CBI") regulates QIAIFs. When Irish public tax scandals concerning the Section 110 SPV, also regulated by the CBI, emerged in 2016–2017, the CBI upgraded the little-used LQIAIF, [1] to give the same benefits as Section 110 SPVs, but with full confidentiality and tax secrecy.
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:
Irish Section 110 SPV's use of "Profit Participation Notes" (i.e. artificial internal intergroup loans), is an impediment to corporates using these structures versus established IP-based BEPS tools. [175] [176] Solutions such as the Orphaned Super-QIAIF have been created in the Irish tax code to resolve this.
Ireland's Debt–based BEPS tools (e.g. the Section 110 SPV), have made Ireland the 3rd largest global Shadow Banking OFC, [24] [120] and have been used by Russian banks to circumvent sanctions. [ 121 ] [ 122 ] [ 123 ] Irish Section 110 SPVs offer " orphaning " to protect the identity of the owner, and to shield the owner from Irish tax (the ...
Women make up 51 percent of the U.S. population. And though we are by no means a monolith — in fact, we fall into every ethnic, socioeconomic, religious and ideological group — we have historically been underrepresented politically.
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.