The Finance Bill 2011 published by the Irish Minister for Finance last week proposes a number of amendments to Ireland’s structured finance and securitisation framework, which is contained in Section 110 of the Taxes Consolidation Act 1997. Section 110 has been used in Ireland in relation to securitisation and structured finance transactions for a number of years and is viewed as a very successful regime which has put Ireland at the forefront of these markets. Why? – Because it is critical in any structured finance transaction to minimise any potential taxation leakage which might affect the return for investors. The

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