Advantages and Opportunities of Ireland for CLO Issuers, Structured Finance, and Non-Bank Lending

Abstract

As an onshore, EU, and OECD member state with an extensive double tax treaty network and with its special tax regime for special purpose vehicles (SPVs), Ireland has emerged as a favored location for establishing vehicles to invest in or hold a wide variety of financial assets, including distressed assets. In particular, Ireland has become a domicile of choice for onshore SPVs in Europe, and it is a preferred alternative to the traditional offshore SPV jurisdictions. Irish SPVs have been used for plain-vanilla securitizations, collateralized loan obligations (CLOs) repackaging of receivables, mortgages, loans (both performing and non-performing), less straightforward synthetic transactions, and more unusual securitizations involving infrastructure projects, such as toll roads. They are also used in various other structures, such as aircraft leasing, life settlement issues, and regulated fund structures.