As Ireland continues to strengthen its position as a premier destination for structuring private asset investments. Donal Ryan and Patrick Glover comment on the country’s appeal in terms of it’s regulatory framework, fund structuring options, and a network of legal, accounting, and fund administration providers.
Donal Ryan, Partner, Financial Services Audit at BDO
Q: Debt securities and structured finance have long been key pillars of Ireland’s financial services sector, with Section 110 SPVs and QIAIFs attracting significant international interest. How have these structures evolved in response to market trends, and how are global investment managers leveraging them for capital efficiency?
A: In my view, Ireland has established itself as a leading European jurisdiction for SPVs and structured financing vehicles as a result of 30 years of effort and investment in developing the infrastructure and expertise. The sector now supports thousands of jobs across Ireland, and its success has been partly driven by the country’s favourable investment structures, particularly Section 110 SPVs and QIAIFs.
Section 110 SPVs offer tax neutrality and legal certainty, attracting international capital. To align with global tax standards, particularly the OECD’s Base Erosion and Profit Shifting (BEPS) initiatives, these vehicles now require greater transparency and substance, ensuring they support genuine economic activity.
QIAIFs, on the other hand, have evolved to offer greater flexibility and diversification. These funds allow investment managers to implement a wide range of strategies, including hedge funds, real estate, and private equity. The regulatory framework governing QIAIFs has been continuously refined to enhance investor protection while maintaining Ireland’s competitiveness.
In addition, global investment managers leverage these structures for capital efficiency by taking advantage of Ireland’s legal framework, skilled workforce, and strategic location within the EU.
Q: What is driving Ireland’s Private Equity growth, and how does Ireland compare to other leading fund domiciles for private equity structuring?
A: Ireland’s projected $6.62 billion private equity growth by 2025 is a direct result of its regulatory strength, global connectivity, and investor-friendly policies. It’s suite of fund structuring options – particularly Qualifying Investor Alternative Investment Funds (QIAIFs), Ireland Collective Asset-Management Vehicles (ICAVs) and the recent addition of the revised Investment Limited Partnership (ILPs) - makes it an appealing jurisdiction for private asset managers seeking tax efficiency, operational flexibility, and robust investor protections.
Ireland’s EU membership is also a key differentiator. As the only English-speaking nation in the EU, Ireland ensures seamless access to the EU market, a major advantage over other jurisdictions. Additionally, Ireland’s commitment to adhering to international standards enhances its credibility and confidence among global investors seeking transparent and compliant jurisdictions.
The presence of leading global financial institutions, highly skilled workforce, and a proactive regulatory body further reinforce investor trust.
Compared to other leading fund domiciles such as Luxembourg and the Cayman Islands, Ireland’s competitive edge lies in its dynamic business environment and strategic initiatives to continuously enhance its financial services sector.
Q: Ireland’s Investment Limited Partnership (ILP) regime has undergone significant reform to enhance its competitiveness for private asset funds. How do these changes fit into the broader global private equity and private credit landscape, and where do you see further opportunities for Ireland to strengthen its position as a hub for private markets?
A: The ILP is now Ireland’s flagship partnership vehicle for private asset managers. As an AIFMD-compliant and EU-domiciled common law partnership and following a legislative reform, it completes Ireland’s suite of investment products and aligns with global market trends where managers seek regulatory flexibility, tax efficiency, and robust legal frameworks.
Key enhancements like streamlined registration processes, increased transparency, and investor protections, further improve Ireland’s standing as an attractive domicile for private asset funds. These changes are particularly timely as the global private equity and private credit markets continue to grow, driven by the demand for alternative investment opportunities in a variety of asset classes including sustainable investment vehicles, infrastructure, and real estate.
Looking ahead, Ireland needs to not stand still, but continually evolve in areas such as sustainable finance, technological innovation, and ensuring its tax and regulatory framework remains attractive in this complex geopolitical landscape. How the Funds Sector Review 2030 is actioned will be keenly watched as to how we strategically position Ireland from a private asset investment industry perspective and critical in shaping Ireland’s long-term strategy.
