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The Journal of Structured Finance

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

James Richards and Conor Houlihan
The Journal of Structured Finance Fall 2013, 19 (3) 82-87; DOI: https://doi.org/10.3905/jsf.2013.19.3.082
James Richards
is a partner at Dillon Eustace in Dublin, Ireland.
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  • For correspondence: james.richards@dilloneustace.ie
Conor Houlihan
is a partner at Dillon Eustace in Dublin, Ireland.
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  • For correspondence: conor.houlihan@dilloneustace.ie
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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.

TOPICS: Fixed income and structured finance, developed

  • © 2013 Pageant Media Ltd
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The Journal of Structured Finance: 19 (3)
The Journal of Structured Finance
Vol. 19, Issue 3
Fall 2013
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Advantages and Opportunities of Ireland for CLO Issuers, Structured Finance, and Non-Bank Lending
James Richards, Conor Houlihan
The Journal of Structured Finance Oct 2013, 19 (3) 82-87; DOI: 10.3905/jsf.2013.19.3.082

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Advantages and Opportunities of Ireland for CLO Issuers, Structured Finance, and Non-Bank Lending
James Richards, Conor Houlihan
The Journal of Structured Finance Oct 2013, 19 (3) 82-87; DOI: 10.3905/jsf.2013.19.3.082
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  • Article
    • Abstract
    • KEY HIGHLIGHTS OF AN IRISH SPV
    • SECTION 110 COMPANY TAXATION
    • FINANCING AND WITHHOLDING TAX ON SECTION 110 COMPANIES
    • PROFIT EXTRACTION FROM SECTION 110 COMPANIES
    • PUBLIC OR PRIVATE COMPANIES
    • LOAN ORIGINATION BY INVESTMENT FUNDS
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