The Irish government is to amend its securitisation regime, under which special purpose vehicles set up to securitise assets receive favourable tax treatment. The legislation was introduced in 1997 to support the international financial services sector in Ireland. However, it is reported that the legislation is now allowing foreign investment funds to pay almost no corporation tax on revenue earned from Irish property interests secured through control of packaged property loans.
Irish finance minister, Michael Noonan, commenting on the proposed amendment to Taxes Consolidation Act 1997, s110, spoke of concerns ‘about the possible use of aggressive tax practices by some section 110 companies to avoid paying tax on Irish property transactions’. The minister said that the amendment is being made to protect the Irish tax base and to ‘ensure that the tax provisions are ring-fenced for bona-fide securitisation purposes’.
The Irish government is to amend its securitisation regime, under which special purpose vehicles set up to securitise assets receive favourable tax treatment. The legislation was introduced in 1997 to support the international financial services sector in Ireland. However, it is reported that the legislation is now allowing foreign investment funds to pay almost no corporation tax on revenue earned from Irish property interests secured through control of packaged property loans.
Irish finance minister, Michael Noonan, commenting on the proposed amendment to Taxes Consolidation Act 1997, s110, spoke of concerns ‘about the possible use of aggressive tax practices by some section 110 companies to avoid paying tax on Irish property transactions’. The minister said that the amendment is being made to protect the Irish tax base and to ‘ensure that the tax provisions are ring-fenced for bona-fide securitisation purposes’.
