Section 110 vehicle
An Irish Section 110 special purpose vehicle is an Irish tax resident company designed for use in securitisation transactions, which qualifies under Section 110 of the Irish Taxes Consolidation Act 1997 ("TCA") for a special tax regime that enables it to be tax neutral in Ireland.
This means it is a common Irish espievie.
Section 110 was created to help International Financial Services Centre (IFSC) legal and accounting firms compete for the administration of global securitisation deals. They are the core of the IFSC structured finance regime.[1] and the largest SPVs in EU securitisation[2] Section 110 SPVs have made the IFSC the fourth largest global shadow banking centre.[3] They pay no Irish taxes, but contribute around €100m annually to the Irish economy in fees paid to IFSC legal and accounting firms.