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  2. Irish Section 110 Special Purpose Vehicle - Wikipedia

    en.wikipedia.org/wiki/Irish_Section_110_Special...

    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.

  3. Qualifying investor alternative investment fund - Wikipedia

    en.wikipedia.org/wiki/Qualifying_investor...

    Qualifying investor alternative investment fund. Central Bank of Ireland ("CBI") regulates QIAIFs. When Irish public tax scandals concerning the Section 110 SPV, also regulated by the CBI, emerged in 2016–2017, the CBI upgraded the little-used LQIAIF, [1] to give the same benefits as Section 110 SPVs, but with full confidentiality and tax ...

  4. Ireland as a tax haven - Wikipedia

    en.wikipedia.org/wiki/Ireland_as_a_tax_haven

    In February 2018, the Central Bank of Ireland, which regulates Section 110 SPVs, upgraded the little used tax-free L-QIAIF regime, which has stronger privacy from public scrutiny. [133] [178] In June 2018, U.S. distressed debt funds transferred €55 billion of Irish assets (or 25% of Irish GNI*), out of Section 110 SPVs and into L–QIAIFs ...

  5. Orphan structure - Wikipedia

    en.wikipedia.org/wiki/Orphan_structure

    In 2016, it was discovered that US distressed debt funds used orphaned SPVs, known as Section 110 SPVs, to buy Irish distressed assets during the Irish financial crisis to avoid Irish taxes. By the time the loopholes were closed by the Irish Government, material amounts of tax revenues were lost to the Irish exchequer. [15] [16] [17]

  6. Apple's EU tax dispute - Wikipedia

    en.wikipedia.org/wiki/Apple's_EU_tax_dispute

    The issue was Apple's variation of the Double Irish tax system, which, from 2004 to 2014, Apple used to shield €110.8 billion [8] [14] of non–US profits from tax. [15] On 9 January 2015, Apple informed the Commission [b] that it closed its hybrid–Double Irish, base erosion and profit shifting (BEPS) tool. [16]

  7. National Asset Management Agency - Wikipedia

    en.wikipedia.org/wiki/National_Asset_Management...

    There was confusion when Dáil deputy Stephen Donnelly asked whether NAMA had knowingly sold assets to bidders with Section 110 SPVs. However, in later disclosures, Finance Minister Noonan stated that NAMA were users of the Section 110 SPVs, and would incur a €158m tax charge as a result of changes Noonan made to Section 110 legislation in ...

  8. Special-purpose entity - Wikipedia

    en.wikipedia.org/wiki/Special-purpose_entity

    A special-purpose entity (SPE; or, in Europe and India, special-purpose vehicle/SPV; or, in some cases in each EU jurisdiction, FVC, financial vehicle corporation) is a legal entity (usually a limited company of some type or, sometimes, a limited partnership) created to fulfill narrow, specific or temporary objectives.

  9. Income Tax (Trading and Other Income) Act 2005 - Wikipedia

    en.wikipedia.org/wiki/Income_Tax_(Trading_and...

    The Income Tax (Trading and Other Income) Act 2005 (c 5) is an Act of the Parliament of the United Kingdom. It restated certain legislation relating to income tax, with minor changes that were mainly intended "to clarify existing provisions, make them consistent or bring the law into line with well established practice." [2]

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