The client, their challenge
The client is one of the largest financial institutions in the Eurozone and one of the top 20 financial institutions in the world for market capitalisation, employing more than 200,000 staff across Europe, the Americas and Asia.
Their experienced global team sought to undertake a securitisation transaction, backed by hire purchase contracts, through Irish S110 companies to avail of Ireland’s extensive and growing double tax treaty network.
Our solution
IQ-EQ engaged with the financial institution in July 2014 to understand their structuring requirements for the Irish S110 company. Our dedicated Irish structured finance team assisted them with all set-up elements of the structure, including establishing bank accounts, registering the S110 companies for the relevant taxes, review of transaction documentation and participating in weekly closing calls.
Our team continue to work closely with the financial institution on the existing structure and the waterfall process.
Results
By choosing Ireland, the client was additionally able to avail of:
- Favourable tax laws allowing the structure to be established in a tax neutral manner
- No Irish stamp duty on the issue of transfer of bonds or notes
- An onshore jurisdiction and a long-standing member of the EU
- Ability to list asset backed debt securities on the Irish Stock Exchange
The first transaction for this client closed in Q4 2014 and IQ-EQ has since assisted with 10 transactions under this structure.
