For many years, Ireland has been a leading jurisdiction in which to establish special purpose vehicles (SPVs) for structured financing transactions. The main reason for this has been the attractive taxation regime for Irish SPVs, commonly known as ‘section 110′ companies in reference to the provision under Irish tax law that forms the basis of the structured financing industry in Ireland. In addition to the tax benefits, a thoughtful legal and regulatory framework and highly-regarded infrastructure of professional advisers and service providers have all contributed to the success of the Irish structured financing industry.
Pre-credit crunch, Ireland had established itself as a location of choice for the establishment of SPVs for an impressive variety of transactions including asset-backed securitisations, repackaging, collateralised debt obligations (CDOs), collateralised loan obligations (CLOs), warehousing, structured investment vehicles (SIVs) and other structured finance transactions.
