As an Irish trading company, the SPV can charge loan interest as an expense (deductible against Irish tax), rather than a deemed profit distribution (not deductible against Irish tax). PPNs are often domiciled in a tax haven (a dutch sandwich may be needed to avoid irish withholding tax transferring the PPN interest payments to the tax haven ).
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Many of the so-called vulture funds buying up mortgages from Irish banks would be international pension or equity funds, which in a lot of cases, would not be regulated to do business in Ireland. Therefore these funds employ local third-party fund managers,
In 2017, Aramark Ireland Holdings posted almost 31 per cent profit growth in its last financial year, 45.8 million gross profit for the year to the end of September 2016, up from 35.1 million for the previous year, according to accounts filed with the Companies Registration Office.
You need a lot of cash, as an individual, or international scale as a company, to pull this off. Typically these things. One group of companies was used to hold the assets of distressed Irish loan.
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A new Irish "not-for-profit" organization headed by Dublin businessman Brian Reilly has officially opened its doors to families and individuals who find themselves in mortgage distress and at.
Vulture Funds may have problems enforcing their securities against distressed borrowers!. Then sell the asset and realise a profit. That is it.. the Irish state could be liable for any losses suffered by the borrower due to the sale of his loan to the vulture fund, as the Irish State did.
The specific features of Irish tax law that enable Section 110 companies to do this include the fact that there are no ‘thin capitalisation’ laws in Ireland (there is no minimum profit required for a company for tax purposes, so an SPV can strip out all of its taxable profits if it chooses). Any costs of raising finance are tax-deductible.
Focus Ireland Calls For Govt Action To Protect Irish Homes As Banks Gear Up To Sell Millions Of Property To Vulture funds. focus ireland warned today that thousands more Irish homes are at risk as banks are set to sell many millions of Euros-worth of property to international vulture funds.