Tax seems to be optional for ‘vulture’ SPVs
Ireland being marketed as ‘location of choice’ for special purpose vehicles
Arthur Cox: says SPVs can be set up “in such a way that the transaction should be tax neutral”. Photograph: Kenneth O’Halloran
Ireland is being marketed abroad by Irish law firms and accountancy practices as “the location of choice” for special purpose vehicles (SPVs) holding all sorts of risky assets across the world.
SPVs are supposed to pay corporation tax of 25 per cent, double the normal rate, but the set-up can be rigged to avoid paying any corporation tax.
Here are a few typical examples of how Ireland is sold as a location for SPVs.
Dillon Eustace, the Dublin law firm, has published a brochure aimed at international funds boasting that any corporation tax liability can “be eliminated with appropriate structuring”.
Maples & Calder tells potential SPV customers “it is generally possible to structure a transaction so there is little or no taxable profit”.
Matheson: “Through proper and careful planning, the position can be achieved such that the SPV earns a minimal [taxable] profit.”
Arthur Cox says SPVs can be set up “in such a way that the transaction should be tax neutral. As a result, Ireland is an ideal jurisdiction . . .”
Ideal for whom?
A quick look at the books of many of the SPVs shows that despite most of them generating millions of euro annually in investment income, they all pay little or no corporation tax.