Favourable tax for section 110

Hybrid Structured Credit Funds: Securitisation moves into new paradigm


A section 110 company provides an onshore platform in an environment of increased international focus on tax havens and principles of the Organisation for Economic Development (OECD), especially transparency. In practice a section 110 company can be almost tax-neutral from an Irish perspective. All profit-participating interest payments should be tax-deductible, as should swap payments, management fees, service fees, and other funding costs.

There is no withholding tax on interest payments made