Irish SPVs on the rise: Tax and operational advantage in the global market

Authored by FlexFunds
spv irlandeses ventaja fiscal operativa (1)
spv irlandeses ventaja fiscal operativa (1)
  • Below we detail why Ireland has become one of the most popular countries for the establishment of SPVs and its role in asset securitization, according to the III Annual Report of the Asset Securitization Sector.
  • The information is mainly intended for asset managers who wish to develop SPVs and build strategies with structured products.
  • FlexFunds offers an asset securitization program with Irish SPVs that stands out for its multiple advantages and cost-efficiency. For more information, feel free to contact our experts.

Many global financial service providers have chosen Ireland as the base for the issuers of their exchange-traded product (ETP) platforms. 

This decision reflects Ireland’s solid reputation as one of the world’s leading jurisdictions for the establishment of SPVs (special purpose vehicles) used in structured finance and capital markets transactions.

Why are Irish SPVs becoming increasingly popular?

Ireland’s popularity as a jurisdiction is reflected in the number of securitization special purpose vehicles (SPVs) it hosts.

As of the end of Q1 2025, Irish securitization SPVs accounted for 30.4% of vehicles of this type in the euro area and 26.8% of the region’s assets.

The choice is driven by several key attributes of the country:

  1. Onshore jurisdiction, member of the European Union (EU) and the Organisation for Economic Co-operation and Development (OECD). As an EU member state, Ireland benefits from the EU’s financial services regulatory framework and the protections it provides.
  2. The only fully operational common law jurisdiction in the EU, with experienced and predictable courts and extensive expertise in resolving complex commercial and financial disputes.
  3. Efficient and transparent tax regime, along with a broad network of double taxation treaties.
  4. Special tax regime (under Section 110 of the Taxes Consolidation Act of 1997) that allows an Irish SPV, under Section 110, to transfer its income to investors in a tax-efficient manner.
  5. Extensive listing options, including the Vienna MTF, Euronext Dublin (the world’s largest bond listing market), the International Stock Exchange, and the London Stock Exchange.
  6. A highly developed service provider infrastructure of auditors, lawyers, corporate service providers, and other professionals to advise and manage SPVs.

Expert analysis on Ireland’s SPVs

According to Daragh O’Shea and Andrew Gill, partners in Debt Capital Markets, Structured Finance and Derivatives at Mason Hayes & Curran: “The range of benefits offered by Ireland’s SPV framework is unmatched by any of its European or global competitors which has contributed to the continued growth in the use of Irish SPVs.”

The Central Bank of Ireland publishes periodic statistical reports on the number of SPVs domiciled in the country and the types and volumes of assets they manage.

By the end of Q1 2025, Ireland reached an all-time high of 3,649 resident SPVs, managing a total of EUR 1.18 trillion in assets.

This volume of activity reflects the deep expertise and familiarity of service providers and market participants, consolidating a solid and reliable ecosystem.

“This combination reinforces Ireland’s position as a leading and cost-efficient jurisdiction, offering investors legal certainty and a sophisticated infrastructure of specialist service providers,” O’Shea and Gill stated in the III Annual Report of the Asset Securitization Sector.

Among the companies that chose Ireland as the base for their SPVs, FlexFunds stands out as a leading asset securitization player, with over USD 1.5 billion in assets under service, more than 500 issuances across 30+ countries, and over 200 clients worldwide.

“FlexFunds has leveraged this environment by building a series of efficient, reliable issuance platforms that capitalize on the advantages of Irish-incorporated SPVs. This approach is gaining traction globally, with 91% of Irish SPVs established by international sponsors, 70% of whom are based in the UK or the US,” O’Shea and Gill detailed.

How FlexFunds leverages Irish SPVs

It is worth noting that the Irish financial ecosystem offers multiple structuring alternatives beyond SPVs, including regulated investment funds, which remain an attractive option.

However, ETP platforms, such as those developed by FlexFunds, are gaining traction due to their flexibility and efficiency. Unlike funds, which are structured with equity securities, ETPs issue debt securities, expanding access to different investor profiles.

In addition, their lighter regulatory framework allows them to reduce costs and provide greater freedom in asset selection and return design.

“FlexFunds’ ETP platforms leverage these advantages by offering asset managers turnkey and customised solutions covering accounting, corporate administration, and full product launch coordination. This enables asset managers to concentrate on strategy and growth, supported by reliable infrastructure and comprehensive regulatory compliance,” explained Mason Hayes & Curran executives.

They added: “The tax efficiency, legal certainty, and operational strength of Ireland’s SPV framework give FlexFunds a distinct competitive edge in the global structured finance landscape.”

To gain deeper insights into asset securitization and the role of SPVs, you can download the III Annual Report of the Asset Securitization Sector 2025–2026, prepared by FlexFunds in collaboration with Funds Society, which provides specific statistics on this ever-growing sector.

Disclaimer:

The purpose of content of the above article, blog, or post is only informational, and it is not intended to provide any sort of investment advice, as an offer of solicitation to buy, sell, or hold, or as recommendation, endorsement of any security, investment, fund and / or company. The content and information provided in the above article, blog, or post does not constitute financial, trading, or investment advice of any type. Neither FlexFunds ETP nor FlexFunds Ltd. is a U.S. registered broker-dealer, or an investment adviser registered with the U.S. Securities and Exchange Commission. Our entities do not raise capital for clients or the Issuers. We do not solicit any specific products, nor offer investment advice or make investment recommendations, nor do we offer tax, legal, financial advice or otherwise. Perform your own due diligence and consult a financial advisor prior to making any investment decision.

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III Annual Report

Asset Securitization Sector
2025 - 2026

Download the report and access the key trends shaping the future of asset securitization, according to over 100 managers and industry experts.

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FlexDual Portfolio Details

Dual Custody: Securitizes a strategy with listed assets in a Bank of New York & Interactive Brokers accounts

Applications

  • Bankability: Global distribution of a strategy
  • Centralized managed account
  • Fund creation alternative
  • Custody of locally listed bonds
  • Design a mixed investment strategy of fixed income, equities, and derivatives

Advantages

  • Trading and custody platform with available leverage
  • Efficient subscription through Euroclear
  • Actively managed by a Portfolio Manager
  • No limitations on rebalancing or portfolio composition
  • Cost efficient
  • Flexibility in the choice of executing broker for underlying trades

FlexRegulated Portfolio Details

Securitizes a strategy with listed assets in an Interactive Brokers account targeting institutional and retail investors

Applications

  • Global distribution of a strategy
  • Centralized managed account
  • Regulated fund creation alternative

Advantages

  • Trading and custody platform with available leverage
  • European UCITs compliant
  • Market to institutional and retail investors
  • Actively managed by a Portfolio Manager
  • Market maker as part of the solution
  • Low value tickets
  • Cost efficient

FlexOpen Portfolio Details

Securitizes a strategy with listed assets in any custodian account

Applications

  • Global distribution of a strategy
  • Centralized managed account
  • Regulated fund creation alternative

Advantages

  • Manage portfolios from any major custodian
  • Introducing Broker Dealers maximize revenue from own trading fees structure
  • AUM remain on the introducer broker agreement
  • Efficient subscription through Euroclear
  • Actively managed by the Portfolio Manager
  • No limitations on rebalancing or portfolio composition
  • Cost efficient

FlexPortfolio Details

Securitizes a strategy with listed assets in a Bank of New York or Interactive Broker custodian account

Applications

  • Global distribution of a strategy
  • Centralized managed account
  • Fund creation alternative
  • Custody of locally listed bonds

Advantages

  • Efficient subscription through Euroclear
  • Actively managed by a Portfolio Manager
  • No limitations on rebalancing or portfolio composition
  • Cost efficient
  • Flexibility in the choice of executing broker for underlying trades
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Welcome to FlexFunds

We provide our services under the Global Note Programs through several entities that perform different activities. Among these entities are FlexFunds ETP LLC which acts as Calculation Agent, and FlexFunds Ltd, which acts as the Program Coordinator. Before making a decision to invest in the Global Note Programs, you should consider the following:

  1. Independent entities. FlexFunds ETP and FlexFunds Ltd. are not managers of the special purpose vehicles, collectively, responsible for the issuance of Notes under the Global Note Programs.
  2. Coordinated Activities. FlexFunds ETP and FlexFunds Ltd act as coordinators of the different entities participating in the Global Note Programs. However, each of the entities is responsible for its own duties and activities in the process.
  3. Not Broker-Dealer or Investment Adviser. Neither FlexFunds ETP nor FlexFunds Ltd. is a U.S. registered broker-dealer or an investment adviser registered with the U.S. Securities and Exchange Commission. Our entities do not raise capital for clients or the Issuers. We do not solicit any specific products, nor offer investment advice or make investment recommendations, nor do we offer tax, legal, financial advice or otherwise.

FlexFunds ETP may collect data about your computer or device, including, where available, your IP address, operating system and browser type, for system administration and other similar purposes.

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Privacy Overview

Welcome to FlexFunds

We provide our services under the Global Note Programs through several entities that perform different activities. Among these entities are FlexFunds ETP LLC which acts as Calculation Agent, and FlexFunds Ltd, which acts as the Program Coordinator. Before making a decision to invest in the Global Note Programs, you should consider the following:

1. Independent entities.FlexFunds ETP and FlexFunds Ltd. are not managers of the special purpose vehicles, collectively, responsible for the issuance of Notes under the Global Note Programs.

2. Coordinated Activities.FlexFunds ETP and FlexFunds Ltd act as coordinators of the different entities participating in the Global Note Programs. However, each of the entities is responsible for its own duties and activities in the process.

3. Not Broker-Dealer or Investment Adviser.Neither FlexFunds ETP nor FlexFunds Ltd. is a U.S. registered broker-dealer or an investment adviser registered with the U.S. Securities and Exchange Commission. Our entities do not raise capital for clients or the Issuers. We do not solicit any specific products, nor offer investment advice or make investment recommendations, nor do we offer tax, legal, financial advice or otherwise.

FlexFunds ETP may collect data about your computer or device, including, where available, your IP address, operating system and browser type, for system administration and other similar purposes.