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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 ...
Orphan structure or Orphan SPV or orphaning are terms used in structured finance closely associated with creating SPVs ("Special Purpose Vehicles") for securitisation transactions where the notional equity of the SPV is deliberately handed over to an unconnected 3rd party who themselves have no control over the SPV; thus the SPV becomes an "orphan" whose equity is controlled by no one.
The Irish Section 110 SPV uses complex securitisation loan structuring (including "orphaning" which adds confidentiality), to enable the profit shifting. This tool is so powerful, it inadvertently enabled US distressed debt funds avoid billions in Irish taxes on circa €80 billion of Irish investments they made in 2012-2016 (see Section 110 ...
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.
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.
Matheson (previously Matheson Ormsby Prentice), is an Irish law firm partnership based in the IFSC in Dublin, which specialises in multinational tax schemes (e.g. for clients in Ireland such as Microsoft, Google [4] and Abbot [5]), and tax structuring of special purpose vehicles (e.g. Section 110 securitisation SPVs). Matheson is estimated to ...
Section 110 is a major global SPV (largest EU securitisation SPV) and I think is worth ensuring that everything is captured properly. Also involved in some abuses as well Britishfinance 17:45, 24 April 2018 (UTC)