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IPS152 Giovanna B. et al.
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                  uninformative  (see  Figure  3) .  Looking  at  the  thresholds  on  the  portfolio
                  composition suggests that the most common strategy is pass-through  (26
                  vehicles), followed by mixed_ass_liab (8 vehicles). Irish sponsored vehicles are
                  mainly  mixed_liab_ass,  investing  the  resources  domestically  and  raising
                  resources abroad.


























                  Investment fund linked
                     This case study outlines a structure in which an Irish SPE is set up for tax
                  efficiency. The sponsor of the Irish SPE is a foreign investment manager of an
                  Irish-resident  investment  fund.  These  fund  units  are  owned  by  foreign
                  investors.  The  Irish  SPE  receives  a  profit  participating  loan  from  the  Irish
                  investment fund and uses the proceeds to purchase foreign debt securities.
                  In return, the fund receives interest dependent on the performance of the
                  SPE’s assets. The Irish SPE is wholly owned by the Irish resident fund and
                  declares to be consolidated into its accounts.












                  3  Assets and liabilities are analysed separately. Columns that overlap at the higher end, do not
                  translate into pass-through entities.
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