Quoted Eurobond exemption
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The Law and Lore of Repackaging
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Ireland
The general principle is that an Irish resident company must withhold on all payments of “yearly” interest. Section 110 companies — repackaging vehicles — can avail themselves of a number of exceptions, one of the most popular of which is the “quoted Eurobond exemption”. This applies to interest paid on the vehicle’s “quoted Eurobonds” — interest-bearing debt securities that are listed on a “recognised stock exchange” as long as the interest payments are made by a paying agent outside Ireland.
“Recognised stock exchange” is not defined, which gives issuers a degree of flexibility, or nervousness, depending on their disposition, when choosing where to list.