Irish Section 110 Special Purpose Vehicle
An Irish Section 110 special purpose vehicle (SPV) or section 110 company is an Irish tax resident company, which qualifies under Section 110 of the Irish Taxes Consolidation Act 1997 (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties.
International Financial Services Centre. Section 110 SPVs were created in 1997 to allow IFSC law firms administer securitisation business; in 2012 these firms would use the SPVs to assist U.S. distressed debt funds shelter over €40 billion of Irish investments (€80 billion in loan balances) from Irish tax.
Finance Minister Michael Noonan moved to partially close some of the abuses of Section 110 SPVs by U.S. distressed debt funds in the Irish domestic economy in the 2016 Finance Act, but controversially decided against full closure, or any investigation or Irish Revenue Commissioners sanction.
Minister Charlie McCreevy's landmark 1997 Tax and Consolidation Act created Section 110 SPVs and laid the foundations for Ireland's leading corporate BEPS tools.
Irish Debt Securities Association (IDSA) launch in 2013 with Minister Richard Bruton, IDSA CEO Gary Palmer, and IDSA Chairman Turlough Galvin of Matheson’s Tax Practice.
Corporation tax in the Republic of Ireland
Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.
Former Finance Minister, Charlie McCreevy, reduced Irish corporate tax from 32% to 12.5% in the 1999 Finance Act, and whose 1997 Tax and Consolidation Act laid the framework for Ireland's BEPS tax tools.
Ireland is ranked as one of the largest global Conduit OFCs in terms of connections to corporate tax havens, the largest global Tax Haven in terms of quantum of profits shielded, and the 3rd-largest global Shadow Banking OFC.
Irish Corporation Tax as a % Irish Exchequer Tax has between 10% and 16% of Total Irish Tax. Source: Department of Finance (Ireland)
Effect of Ireland's Corporate Tax system on Ireland's relative GNI-per-capita to the EU average
