The tax neutral features of Irish SPVs are an essential attraction of them in structured finance. Aidan Walsh examines the broader context of tax, and the impact that the OECD’s Action Plan on base erosion and profit shifting (BEPS) last month may have on structured finance. The action plan intends to deal with core structured finance strategies like treaty access, interest deductions, transfer pricing, allocation of risk and capital, hybrid entities and hybrid instruments.
