Ireland is a leading jurisdiction for the establishment of special purpose vehicles (“SPVs”) for structured finance transactions. Favourable tax laws allow the structures to be, in most cases, tax neutral (with no annual minimum profit or “spread” required at the SPV level) and a “quoted eurobond” exemption, together with numerous double taxation treaties, allows interest on securities to be paid gross. A minimal share capital requirement of €1 in most cases makes incorporating an Irish SPV an easy process.
Additionally, the Irish Stock Exchange is a market leader in the listing of debt securities. The predominant reasons for Ireland’s popularity as an SPV location are its favourable tax regime, the fact that it is an “on-shore” jurisdiction, its developed corporate legal system and the professional and administration services that are available locally.