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Structured Finance (Section 110)


Section 110 is at the heart of Ireland’s structured finance regime. It allows for organisations to achieve a neutral tax position provided certain conditions are met. This regime, which has been in existence since 1991, is widely used and internationally regarded.

What is Section 110?

A Section 110 company is an Irish resident special purpose vehicle (SPV) which holds and/or manages “qualifying assets”. This facility is often used as an onshore investment platform in an environment where there is an increased international focus on tax havens and transparency.

Which assets qualify?

Qualifying assets include a wide range of financial assets, commodities and plant and machinery.

Who uses it?

It’s widely used by international banks, asset managers and investment funds for securitisations, investment platforms, Collateralised Loan Obligations (CLO’s), Collateralised Debt Obligations (CDO’s), Loan Participation Note (LPN) transactions, capital market bond issuances and asset lessors.

What’s the benefit?

The ability to operate within an onshore regime is attractive to many investors due to the stability of the regime and its cost efficient nature. This is particularly important in times of uncertain economic markets. In addition, a Section 110 company qualifies for the benefits of Ireland’s double tax treaty network which should reduce or eliminate withholding taxes on income flows and capital gains in treaty jurisdictions.

Why Ireland?

Ireland is an extremely attractive location for establishing investment platforms due to its flexible legal, regulatory and tax environment. From a tax perspective, Ireland provides a number of benefits including:

  • flexible and favourable domestic tax law reliefs
  • allows for corporation tax neutral treatment provided certain conditions are met
  • access to a wide and expanding tax treaty network
  • the absence of debt equity requirements
  • the absence of controlled foreign corporation legislation
  • a well-established international financial centre

How can we help?

Our structured finance team have vast experience in helping companies establish efficient investment structures. We are passionate about delivering the best solutions for you and your business. In recognition of the international tax issues to be considered in structuring funds, our specialised tax team works extensively with our global international tax teams on an ongoing basis. We can help with the following:

  • Formulating effective strategies for optimising taxes
  • Implementing efficient structures
  • Effectively maintaining compliance

Contact us

Colin Farrell

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 6345

Harry Gleeson

Director, PwC Ireland (Republic of)

Tel: +353 1 792 6533

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