Structured Finance Guide - SPVs in Ireland (for Russian LPNs), August 2007
24.08.2007
Ireland has firmly established itself as a jurisdiction for the location of special purpose vehicles (SPVs) for structured finance transactions, particularly Russian Loan Participation Note (LPN) and other corporate fundraising structures. Favourable tax laws allow the structures to be, in most cases, tax neutral and a "quoted eurobond" exemption, together with the advantageous Irish-Russian double taxation treaty, allows interest on loans between Irish SPVs and Russian counterparties to be paid gross in most cases.
