Irish Section 110 Special Purpose Vehicle (English Wikipedia)

"Vulture funds rub salt into the carcass of this country". David McWilliams Sunday Business Post. 1 August 2016. Archived from the original on 19 March 2018. Retrieved 18 March 2018.

dilloneustace.com

"Ireland as a domicile for Special Purpose Vehicles" (PDF). Dillon Eustace. 2016.
"Holding Companies in Ireland" (PDF). Dillon Eustace Law Partners (Dublin). 2016.
"A Guide to Investing in QIAIFs" (PDF). Dillon Eustace. November 2015.
"Central Bank of Ireland publishes notice of intention to amend the requirements for Loan Origination Qualifying Investor AIF" (PDF). Dillon Eustace Law Firm. February 2018.

dilloneustace.ie

"Irish Structures for investing in Distressed Assets" (PDF). Dillon Eustace Law Partners (Dublin). 2010.

doi.org

Stewart, Jim; Doyle, Cillian (February 2017). ""The measurement and regulation of shadow banking in Ireland", JFRC Vol. 25 Issue: 4, pp.396-412". Journal of Financial Regulation and Compliance. 25 (4): 396–412. doi:10.1108/JFRC-02-2017-0019.
Garcia-Bernardo, Javier; Fichtner, Jan; Takes, Frank W.; Heemskerk, Eelke M. (13 March 2017). "Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network". Scientific Reports. 7 (1): 6246. arXiv:1703.03016. Bibcode:2017NatSR...7.6246G. doi:10.1038/s41598-017-06322-9. PMC 5524793. PMID 28740120.

dublininquirer.com

"ANDY: CONSOLE WAS BAD, CORPORATE TAX AVOIDANCE IS FAR WORSE". Dublin Inquirer. 26 July 2016. Archived from the original on 3 July 2022. Retrieved 27 April 2018.
"VULTURE FUNDS GORGE ON IRELAND BECAUSE THE GOVERNMENT LETS THEM". Dublin Inquirer. 16 March 2016. Archived from the original on 30 November 2022. Retrieved 25 April 2018.

emmaclancy.com

"How do vulture funds manage to pay practically no tax in Ireland?". Emma Clancy. 30 July 2016.

eyfinancialservicesthoughtgallery.ie

"The Irish Section 110 Company" (PDF). Ernst and Young (Dublin). 2014.

finance-magazine.com

"An Introduction to Securitisation in Ireland Dillon Eustace Law". July 2002.
"Securitisation to grow further in 2003". January 2003.
"KPMG calls for removal of Irish withholding tax controls on Section 110 SPVs". July 2002.
"Matheson 2006 Finance Act extends quoted Eurobond withholding tax exemption for Section 110 SPVs". Finance Dublin. September 2006.
"Securitisation industry lobby Government to amend Companies (Auditing & Accounting) Bill". Finance Magazine. January 2003.
"PwC calls for Section 110 to be exempted from 2005 Finance Bill". Finance Magazine. 2005.

financedublin.com

"A&L Goodbody lobbies for Section 110 changes in 2003 Finance Act". Finance Dublin. January 2003.
"Securitisation framework modernised and IFSC non IFSC distinction removed". March 2003.
"Finance Bill 2016 Amendments to Securitisation Regime". Finance Magazine. January 2017.

flightglobal.com

"Brazil's Tax Haven Verdict on Ireland". Flight Global. November 2016.

fora.ie

"The vulture fund paying very little tax on its billion-euro Irish incomes". FORA. 13 March 2016.

fsb.org

"Global Shadow Banking and Monitoring Report: 2017" (PDF). Financial Stability Forum. 5 March 2018. p. 30. Jurisdictions with the largest financial systems relative to GDP (Exhibit 2-3) tend to have relatively larger OFI [or Shadown Banking] sectors: Luxembourg (at 92% of total financial assets), the Cayman Islands (85%), Ireland (76%) and the Netherlands (58%)

fstaxation.ie

"Irish Qualifying Investor Funds and Section 110 Companies" (PDF). FS Taxation. October 2013. Archived from the original (PDF) on 14 November 2017. Retrieved 18 March 2018.

ft.com

"Ireland confronts another tax scandal closer to home". Financial Times. 11 September 2016.
"'Aggressive' vulture funds swoop in on Irish property". Financial Times. 18 February 2017.

gabriel-zucman.eu

Gabriel Zucman; Thomas Torslov; Ludvig Wier (June 2018). "The Missing Profits of Nations". National Bureau of Economic Research, Working Papers. p. 31. Appendix Table 2: Tax Havens

grantthornton.ie

"Irish SPV Taxation" (PDF). Grant Thornton. 30 September 2015.
"Section 110 companies - New notification requirements". Grant Thornton. March 2017.

harvard.edu

ui.adsabs.harvard.edu

Garcia-Bernardo, Javier; Fichtner, Jan; Takes, Frank W.; Heemskerk, Eelke M. (13 March 2017). "Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network". Scientific Reports. 7 (1): 6246. arXiv:1703.03016. Bibcode:2017NatSR...7.6246G. doi:10.1038/s41598-017-06322-9. PMC 5524793. PMID 28740120.

idsa.ie

"Ireland: The Leading European Jurisdiction for SPVs, Structured Finance and Securitised Structures" (PDF). Irish Debt Securities Association. 2016.
"SPVs in Ireland" (PDF). Irish Debt Securities Association (IDSA). 2016.
"Special Purpose Vehicles and the Securitisation Industry in Ireland Q&A" (PDF). Irish Debt Securities Association (IDSA). 2016.

imf.org

"Ireland:Selected Issues". International Monetary Fund. June 2018. p. 20. Figure 3. Foreign Direct Investment - Over half of Irish outbound FDI is routed to Luxembourg

independent.ie

"Ireland is top Eurozone jurisdiction for SPVs". Irish Independent. 19 August 2017.
"Ireland has world's fourth largest shadow banking sector, hosting €2.02 trillion of assets". Irish Independent. 18 March 2018.
"Only lawyers and accountants gain from Irish 'SPVs' - Central Bank". Irish Independent. 5 October 2016.
"'Vultures' minimise their tax bills - as State now appears to have delivered the sale of the century". Irish Independent. 21 August 2016.
"Tax avoidance could run to billions". Irish Independent. 24 July 2016.
"How did the Government shaft mortgage holders and taxpayers in one fell swoop?". Irish Independent. 10 July 2016.
"Noonan is accused of 'rolling out the red carpet for vulture funds'". Irish Independent. 16 March 2015.
"Revenue probes 40 'tax-neutral' companies for suspected abuse". Irish Independent. 24 July 2016.
"Call for SPV shake-up to make Ireland world leader by the IDSA". Irish Independent. 5 October 2017.
"Irish shadow banking dwarfs more traditional sectors". Irish Independent. 17 March 2018.
"Loophole allowing Vulture Funds to pay almost no Irish profit tax shut". Irish Independent. 16 September 2016.
"Project Eagle's potential loss bigger than £190m". Irish Independent. 25 September 2016.
"Massive blow to vulture funds as arrears halted due to miscalculations". Irish Independent. 4 January 2018.
"Vulture funds ramp up number of debt chase cases tenfold". Irish Independent. 4 September 2017.
"Cardinal Capital warns of damage by new S110 Rules". Irish Times. 11 September 2016.
"Vulture funds are feasting tax-free on carcass of our property crash". Irish Independent. 30 August 2016.
"'We don't want brass plate firms that come for tax advantages'". Irish Independent. 24 November 2016.
"Azerbaijan's biggest bank raised $900m via Irish SPVs before default". Irish Independent. 20 June 2017.
"Russian bank collapse shines light into shadowy corners of Irish finance". Irish Independent. 25 February 2016.
"'Strong evidence' Ireland is facilitating tax avoidance for major banks - Oxfam". Irish Independent. 27 March 2017.

internationaltaxreview.com

"Irish Securitisation Section 110 Vehicles". International Tax Review. 15 March 2015.

irishexaminer.com

"Wealthy firms 'using charitable status to avoid paying taxes'". Irish Examiner. 13 July 2016.
"Row as Noonan is accused of being a 'vulture-fund lover'". Irish Examiner. 18 May 2016.

irishlegal.com

"Master of the High Court says vulture funds may be exploiting another tax loophole". Irish Legal News. July 2017. Archived from the original on 13 July 2018. Retrieved 18 March 2018.

irishtimes.com

"How do vulture funds exploit tax loopholes?". Irish Times. 17 October 2016.
"Noonan's efforts to tax 'vulture' funds seen as ineffective". Irish Times. 3 October 2016.
"IMF queries lawyers and bankers on hundreds of IFSC boards". The Irish Times. 30 September 2016.
"A third of Ireland's shadow banking subject to little or no oversight". The Irish Times. 10 May 2017.
"Ireland is the world's biggest corporate 'tax haven', say academics". Irish Times. 13 June 2018. New Gabriel Zucman study claims State shelters more multinational profits than the entire Caribbean
"Law firm defends use of charities to help hedge funds cut tax bills". Irish Times. 27 August 2015.
"Revenue queries use of registered charities in "shadow banking"". Irish Times. 27 July 2016.
"Irish Charities Regulator rejects Matheson Charities in Section 110 SPVs". Irish Times. 28 April 2017.
"Lawyers and accountants share in €100m fees from SPVs in IFSC". Irish Times. 4 October 2016.
"Irish special purpose vehicle assets reach €763bn". Irish Times. 18 July 2017.
"Tax-free funds once favoured by 'vultures' fall €55bn: Regulator attributes decline to the decision of funds to exit their so–called 'section 110 status'". Irish Times. 28 June 2018.
"Loophole lets firms earning millions pay €250 tax, Dáil told". Irish Times. 6 July 2016.
"Dublin unit of US hedge fund with $8bn assets pays $125 tax". Irish Times. 15 August 2016.
"Cerberus paid €1,900 tax on €77m Project Eagle profits". Irish Times. 29 November 2016.
"Vulture funds using charities to avoid paying tax, says Donnelly". Irish Times. 14 July 2016.
"State-backed funds using Section 110 to slash tax bill". Irish Times. 2 July 2017.
McGreevy, Ronan (28 August 2016). "Central Bank landlord a vulture fund paying no Irish tax, says SF". The Irish Times. Irish Times. Retrieved 21 September 2024.
"Revenue warns firms over sale of loans to vulture funds". Irish Times. 26 March 2016.
"Lawyers and accountants share in €100m fees from SPVs in IFSC". Irish Times. 4 October 2016.
"Michael Noonan to target vulture funds with €50m tax bill". Irish Times. 11 October 2016.
"Nama paid €158m in tax after section 110 loophole closure". Irish Times. 1 February 2017.
"US vulture funds lobbied Government over proposed tax changes". Irish Times. 21 January 2017.
"Tax-free funds once favoured by 'vultures' fall €55bn: Regulator attributes decline to the decision of funds to exit their so-called 'section 110 status'". Irish Times. 28 June 2018.
"More than €100bn in Russian Money funneled through Dublin". The Irish Times. 4 March 2018.
"Ireland is world's fourth-largest shadow banking hub". The Irish Times. 10 May 2017.
"Former Regulator says Irish politicians mindless of IFSC risks". The Irish Times. 5 March 2018.
"Irish SPVs more a worry for other countries than State". The Irish Times. 13 January 2017.

kpmg.com

assets.kpmg.com

"KPMG Ireland: QIAIFs" (PDF). KPMG. November 2015.

kpmg.ie

"KPMG Finance Bill 2016 Taxing Times" (PDF). KPMG. November 2016. Archived from the original (PDF) on 22 November 2017. Retrieved 27 April 2018.

maplesandcalder.com

"International and Irish CG50 Tax Update July 2016". Maples and Calder. 14 July 2016.

matheson.com

"CENTRAL BANK OF IRELAND: Enhancements to the L–QIAIF regime announced". Matheson (law firm). 29 November 2016.
"CENTRAL BANK OF IRELAND: Enhancements to the L-QIAIF regime announced". Matheson (law firm). 29 November 2016.

mccannfitzgerald.com

"Changes to Section 110 of the Taxes and Consolidation Act of 1997" (PDF). McCann Fitzgerald. September 2016.

mhc.ie

"Ireland's Super QIF" (PDF). Mason Hayes+Curran Law. 2012.

nih.gov

ncbi.nlm.nih.gov

Garcia-Bernardo, Javier; Fichtner, Jan; Takes, Frank W.; Heemskerk, Eelke M. (13 March 2017). "Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network". Scientific Reports. 7 (1): 6246. arXiv:1703.03016. Bibcode:2017NatSR...7.6246G. doi:10.1038/s41598-017-06322-9. PMC 5524793. PMID 28740120.

pubmed.ncbi.nlm.nih.gov

Garcia-Bernardo, Javier; Fichtner, Jan; Takes, Frank W.; Heemskerk, Eelke M. (13 March 2017). "Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network". Scientific Reports. 7 (1): 6246. arXiv:1703.03016. Bibcode:2017NatSR...7.6246G. doi:10.1038/s41598-017-06322-9. PMC 5524793. PMID 28740120.

nytimes.com

"Wall Street is Europe's landlord and tenants are fighting back". New York Times. 10 December 2016.

oxfamireland.org

"MANTRAS AND MYTHS: A true picture of the corporate tax system in Ireland" (PDF). RTÉ News. February 2017. Archived from the original (PDF) on 3 October 2017. Retrieved 7 April 2018.

pecloserlook.org

"Oaktree, Mars Capital and Section 110" (PDF). UNITE HERE. February 2017. Archived from the original (PDF) on 26 April 2018. Retrieved 25 April 2018.

pwc.com

"Brazil Adds Ireland to Tax Haven List". PWC Ireland. September 2016.

pwc.ie

"Structured Finance (Section 110)". PWC Ireland. 2016.
"The meaning of changes to Section 110". PWC Ireland. September 2016.

revenue.ie

"Section 110: entitlement to treatment" (PDF). Revenue Commissioners. May 2018.
"Notification to be a 'qualifying company' Section 110" (PDF). Revenue Commissioners. February 2018.
"Exemption from Encashment Tax for "Qualifying Company" within the meaning of Section 110 of the Taxes Consolidation Act, 1997". Irish Revenue. 14 January 2010.

rte.ie

"Government moves to amend Section 110 to close tax loophole used by vulture funds". RTÉ News. 6 September 2016.
"German bank losses prompt IFSC raid". RTÉ News. 13 August 2008.
"Public Accounts Committee Noonan ill-advised on fund meeting". RTÉ News. 3 April 2017.
"Ireland could be potential tax haven under EU rules - Oxfam". RTÉ News. 28 November 2017.

scribd.com

"Ireland as a location for Distressed Debt: Super QIF Example". Davy Stockbrokers. 2014.

stephendonnelly.ie

"WHY LETTING SECTION 110 SPVS OPERATE IN THE IRISH DOMESTIC ECONOMY WILL DAMAGE OUR TAX BASE AND OUR REPUTATION AS A 'LOW-TAX' ECONOMY" (PDF). Stephen Donnelly (Dáil Submission). September 2016. Archived from the original (PDF) on 14 November 2017. Retrieved 18 March 2018.
"Why would a Vulture Fund own a Children's Charity". Dáil Éireann. 24 November 2016. Archived from the original on 11 June 2018. Retrieved 18 March 2018.
"Response to the 2016 Finance Bill" (PDF). Stephen Donnelly. November 2016.

tasc.ie

"'Section 110' Companies: A Success story for Ireland" (PDF). Professor Jim Stewart Cillian Doyle. 12 January 2017.
"Ireland, Global Finance and the Russian Connection" (PDF). Professor Jim Stewart Cillian Doyle. 27 February 2018.

thejournal.ie

"Vulture funds pay just €8,000 in tax on €10 billion of assets". thejournal.ie. 8 January 2017.
"Accounting firms are telling vulture funds how to get around tax loophole closure". thejournal.ie. 5 October 2016.
"Tax avoidance clampdown expected to take in €50 million 'should yield €500 million'". thejournal.ie. 12 October 2016.
Christina Finn (27 March 2019). "UN says Ireland applies 'preferential tax laws' to vultures funds and it 'cannot continue'". TheJournal.ie. Retrieved 29 March 2019. A UN SPECIAL Rapporteur on housing has sent a letter to the Irish government noting that they have facilitated housing financing through "preferential tax laws and weak tenant protections among other measures".

thetimes.co.uk

"Apollo's vulture clipped by tax bill". Sunday Times. 17 January 2017.
Gavin Daly (21 April 2019). "Paddy Cosgrave, a weird press conference and €1,000 cash in brown envelopes". The Sunday Times. Retrieved 26 April 2019.

washingtonpost.com

Aidan Regan (25 April 2019). "Ireland is a tax haven — and that's becoming controversial at home". Washington Post. Retrieved 25 April 2019.

web.archive.org

"REVEALED: the vulture funds that paid just €250 in tax". Sunday Business Post. 24 July 2016. Archived from the original on 24 June 2018. Retrieved 27 April 2018.
"WHY LETTING SECTION 110 SPVS OPERATE IN THE IRISH DOMESTIC ECONOMY WILL DAMAGE OUR TAX BASE AND OUR REPUTATION AS A 'LOW-TAX' ECONOMY" (PDF). Stephen Donnelly (Dáil Submission). September 2016. Archived from the original (PDF) on 14 November 2017. Retrieved 18 March 2018.
"KPMG Finance Bill 2016 Taxing Times" (PDF). KPMG. November 2016. Archived from the original (PDF) on 22 November 2017. Retrieved 27 April 2018.
"Vulture funds rub salt into the carcass of this country". David McWilliams Sunday Business Post. 1 August 2016. Archived from the original on 19 March 2018. Retrieved 18 March 2018.
"Ireland as a Domicile for Structured Finance" (PDF). Arthur Cox Law. 2014. Archived from the original (PDF) on 16 March 2018. Retrieved 18 March 2018.
"Irish Qualifying Investor Funds and Section 110 Companies" (PDF). FS Taxation. October 2013. Archived from the original (PDF) on 14 November 2017. Retrieved 18 March 2018.
"Update on Changes to Loan Originating Qualifying Investor AIF Regime" (PDF). Author Cox Law Firm. December 2016. Archived from the original (PDF) on 1 July 2018. Retrieved 1 July 2018.
"Why would a Vulture Fund own a Children's Charity". Dáil Éireann. 24 November 2016. Archived from the original on 11 June 2018. Retrieved 18 March 2018.
"Oaktree, Mars Capital and Section 110" (PDF). UNITE HERE. February 2017. Archived from the original (PDF) on 26 April 2018. Retrieved 25 April 2018.
"ANDY: CONSOLE WAS BAD, CORPORATE TAX AVOIDANCE IS FAR WORSE". Dublin Inquirer. 26 July 2016. Archived from the original on 3 July 2022. Retrieved 27 April 2018.
"VULTURE FUNDS GORGE ON IRELAND BECAUSE THE GOVERNMENT LETS THEM". Dublin Inquirer. 16 March 2016. Archived from the original on 30 November 2022. Retrieved 25 April 2018.
"Master of the High Court says vulture funds may be exploiting another tax loophole". Irish Legal News. July 2017. Archived from the original on 13 July 2018. Retrieved 18 March 2018.
"MANTRAS AND MYTHS: A true picture of the corporate tax system in Ireland" (PDF). RTÉ News. February 2017. Archived from the original (PDF) on 3 October 2017. Retrieved 7 April 2018.

williamfry.com

"Changes to Section 110 Regime Relating to Irish SPVs Holding Irish Property Assets". William Fry Solicitors. 8 September 2016.
"Changes to the Section 110 Regime". William Fry Law Firm. September 2016.
"Irish Loan Originating Funds (L–QIAIFs): An Introduction" (PDF). William Fry Law Firm. February 2018.

wsj.com

"Zucman:Corporations Push Profits Into Corporate Tax Havens as Countries Struggle in Pursuit, Gabrial Zucman Study Says". Wall Street Journal. 10 June 2018. Such profit shifting leads to a total annual revenue loss of $200 billion globally