05 Mar 2026

Ireland as a Jurisdiction for Structured Finance

DAC Structures and Section 110 Tax Neutrality

Ireland has become the leading European jurisdiction for structured finance SPVs, accounting for over 31% of the market by volume. Despite global tax reforms and increased transparency requirements, the country continues to attract securitisation vehicles, aircraft leasing platforms and structured investment entities.

But what actually makes Ireland’s framework durable for complex transactions?

This paper explores the practical role of Designated Activity Companies (DACs) in structured finance structures and explains how the Section 110 regime enables tax neutrality when implemented correctly. Drawing on real transaction experience, Sumant Pradhan, Vice President – Commercial & Strategy at Acumen Aviation, outlines how these structures function in practice and why they remain widely accepted by sponsors, lenders and investors.

Inside the paper, you will learn:

• Why Ireland remains a preferred jurisdiction for securitisation and asset-backed structures

• The practical differences between DAC and LTD corporate vehicles in structured transactions

• How the Section 110 regime works and what conditions must be satisfied

• How tax neutrality is typically achieved using Profit Participating Notes (PPNs)

• A simplified case study comparing Section 110 vs non-Section 110 SPV outcomes

• Governance and execution considerations that determine whether the structure remains robust over time

For sponsors, investors and structuring professionals working across aircraft leasing, securitisation and structured asset platforms, this paper provides a clear commercial perspective on how Ireland’s SPV framework operates beyond the legal definitions.

Download the full paper to understand how DAC structures and Section 110 tax neutrality support durable structured finance transactions.