Ireland - Tax Treatment of Irish Investment Fund and SPV Structures
- J. Sheehan
- Derivatives & Financial Instruments, 2011 (Volume 13), No 5
- 20 September 2011
This article examines the tax treatment of investment fund and structured finance vehicles in Ireland. It considers the availability of double tax treaty relief for Irish funds and certain anti-avoidance measures introduced in 2011 in the context of Ireland’s securitization regime. The article also discusses how the vehicles can be combined to address potential issues at the investor and asset levels.