Irish Section 110 Special Purpose Vehicle
Controversies
Controversies tied to this brand in public sources. A listing is not a finding of fault.
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2017
Oversight and transparency criticism
Academic research characterised many Section 110 SPVs as lightly supervised, low-substance or 'brass plate' entities and reported links to sanctioned or prohibited Russian banks. Broader research also associated Irish SPVs with conduit finance and offshore shadow banking.
2016
Section 110 domestic-investment tax controversy
Public reporting revealed that distressed-debt funds used Section 110 SPVs in transactions involving approximately €80 billion of Irish domestic investments. Critics alleged that the structures enabled avoidance of Irish tax on domestic returns and questioned the absence of effective investigation or enforcement. The controversy led to government action and continuing debate over the boundaries of the regime.