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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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