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How to Set Up an SPV (Special Purpose Vehicle) in Ireland: 2026 Guide

  • Writer: Matthew Ivo
    Matthew Ivo
  • 5 days ago
  • 6 min read
Evening cityscape of a river with a lit bridge and colorful reflections. Historic buildings and trees line the banks under a clear blue sky.

Setting up a Special Purpose Vehicle (SPV) in Ireland is increasingly popular among foreign business owners and international investors. SPVs allow investors to hold assets, manage financial transactions, or structure investments in a legally robust and tax-efficient manner. Unlike traditional property holding companies or standard bank accounts, SPVs offer flexibility, risk isolation, and enhanced reporting structures. This 2026 guide explains how to establish an SPV in Ireland, compares SPV payment accounts with traditional property bank accounts, explores SPV growth trends, and highlights the industries where SPVs are most commonly used.

What is an Irish SPV, and why use one?

An SPV is a company created for a specific, narrow purpose, often to isolate risk, manage particular assets, or execute financial transactions. In Ireland, SPVs typically take the form of limited companies, with some qualifying under Section 110 for special tax treatment.

For foreign business owners, Ireland offers significant advantages:

  • Legal certainty: Ireland is a common-law jurisdiction, an EU member, and globally recognised for corporate governance.

  • Tax efficiency: Ireland has a broad network of double-taxation treaties, reducing withholding tax on dividends or interest.

  • Regulatory clarity: Certain SPV structures are exempt from specific tax and reporting rules that apply to standard trading companies.

  • Flexible corporate setup: SPVs can be incorporated with minimal share capital and tailored to the purpose, from asset management to financing.

SPVs are widely used for holding assets such as receivables, intellectual property, loans, leases, or other financial instruments. They also provide legal protection by ring-fencing specific assets from broader business risks.

Growth of SPVs in Ireland and popular industries

Ireland has seen significant growth in SPV formation. As of 2025:

  • Over 4,100 SPVs were active in Ireland, up 4% from the previous year.

  • Collectively, Irish SPVs held over €1,100 billion in assets, demonstrating international investor confidence.

The most common SPV use cases include:

Sector

Use cases

Securitisation & Structured Finance

CLOs, asset-backed securities, and other structured finance vehicles

Aircraft and Asset Leasing

Ireland remains a global hub for aircraft and equipment leasing SPVs

Investment Funds / Credit Funds

Private credit and investment fund SPVs are increasingly popular

General Asset-Holding

SPVs holding diverse assets such as receivables, IP, or contracts

Ireland accounts for around 24% of European SPV issuances, making it one of the continent’s leading jurisdictions for SPV formation.

How to set up an Irish SPV: step by step

  1. Choose a corporate structure


    Most SPVs are limited companies, such as Designated Activity Companies, with some qualifying under Section 110.

  2. Appoint directors and a company secretary


    SPVs must have a registered office in Ireland, a company secretary, and at least one director (sometimes requiring EEA residency).

  3. Define the purpose and prepare constitutional documents


    Even though SPVs serve a narrow purpose, their articles of association must clearly define the activities permitted.

  4. Meet qualifying asset thresholds


    Section 110 SPVs must hold “qualifying assets” above certain thresholds, including loans, receivables, or intellectual property.

  5. Register with Irish authorities


    Incorporate with the Companies Registration Office (CRO) and, if applicable, register with the Central Bank for regulatory reporting.

  6. Set up operational infrastructure


    Establish bank accounts, appoint administrators or trustees, and ensure ongoing accounting and auditing.



Documents needed to set up an SPV in Ireland (for non-residents)

Setting up an SPV (Special Purpose Vehicle) in Ireland is a popular choice for international investors thanks to Ireland’s strong legal framework and business-friendly environment. If you’re not an Irish resident, the process is still straightforward - you just need to prepare the right documents.

Below is a simple, clear checklist of what you’ll need.

1. Proof of Identity

Each director, shareholder, and beneficial owner must provide:

  • A passport copy (usually certified or notarised)

  • Proof of residential address, such as a utility bill or bank statement (typically dated within the last 3 months)

2. Corporate Structure Details

You’ll need to provide:

  • Names, addresses, and contact details for directors and shareholders

  • Details of the company secretary

  • Information about the ultimate beneficial owners (UBOs) who control more than 25% of the SPV

  • A registered office address in Ireland (must be a real address, not a PO box)

3. Constitution / Company formation documents

To incorporate the SPV, you must file:

  • The company constitution (Ireland’s version of Articles of Association)

  • The incorporation form with basic company information (name, activity, share capital, directors, etc.)

These are usually prepared for you by a formation agent or corporate services provider.

4. Non-resident director requirements

If none of the directors lives in the EU/EEA, you must meet one of the following:

  • Appoint an EEA-resident director, or

  • Put in place a Section 137 Non-Resident Director Bond

    • Most non-resident SPVs use the bond option.

5. Post-Incorporation documents

Once the SPV is formed, you’ll receive or need to prepare:

  • Share certificates

  • Statutory registers (directors, shareholders, UBOs)

  • First board meeting minutes confirming appointments and share allotments

These documents are typically included in incorporation packages.

6. Extra considerations for SPVs (Section 110 structures)

Depending on the type of SPV, you may also need:

  • Beneficial Ownership Register filing

  • Tax registrations (if the SPV trades or earns income)

Compliance considerations for Irish SPVs

Irish SPVs are not “set-and-forget” structures. Compliance includes:

  • Filing annual returns with the CRO

  • Reporting financial transactions to the Central Bank (for regulated SPVs)

  • Maintaining arm’s-length transactions if using Section 110 tax benefits

  • Monitoring and segregating funds per asset or property to maintain transparency

Failure to comply can result in loss of tax benefits or regulatory penalties, highlighting the need for experienced Irish-based corporate service providers.

SPV accounts vs traditional property bank accounts in Ireland

Many investors are familiar with standard Irish property bank accounts. While these accounts suffice for basic rent collection or mortgage payments, SPV accounts offer specialised features designed for international, multi-asset portfolios:

Feature

Traditional property bank account

Currency management

Limited currencies often require multiple accounts

Manage 50+ currencies in a single account, avoiding FX fees

Global payments

Can be slow or restricted for international transfers

Make high-value payments in 160+ countries quickly and securely

Fund segregation

Typically, one account for multiple properties

Each property or investment can have its own account for clarity and compliance

Cash flow & reporting

Manual tracking, prone to errors

Automated reconciliation, smart cash flow monitoring, and simplified tax reporting

Expert support

Standard bank support

Dedicated Relationship Manager for international transactions and portfolio advice

SPV accounts are particularly beneficial for foreign investors, landlords, or fund managers who need efficient cross-border payments and centralised fund management.

Why Interpolitan Money is better than a bank

While high street banks remain the go-to for everyday banking, their offerings often fall short for investors navigating complex, cross-border markets. Interpolitan Money’s SPV accounts are specifically designed to tackle these challenges:

  • Manage currencies easily: Hold, convert, and manage 50+ currencies in a single account.

  • Send and receive globally: Make high-value payments in 160+ countries quickly and securely.

  • Separate funds per property: Keep each property or investment in its own account for clarity and compliance.

  • Expert support: Dedicated Relationship Managers guide international transactions and portfolio management.

  • Smart cash management: Automate reconciliations, monitor cash flows, and optimise capital allocation.

Whether you’re funding acquisitions, managing rental income, or investing internationally, an SPV account from Interpolitan Money provides control, efficiency, and simplicity that traditional banks cannot match.

 



FAQ: Forming an SPV in Ireland

What are the key steps to set up an SPV in Ireland as a foreign investor in 2026?

Set up an SPV by choosing a company structure, appointing directors, preparing constitutional documents, registering with the CRO, and opening an SPV account. Some SPVs may also require Section 110 qualification and Central Bank reporting.

Which documents do non-residents need to form an SPV in Ireland?

Non-residents need a certified ID, proof of address, director and shareholder details, a registered Irish office address, and a company constitution. A Section 137 Director Bond is required if there is no EEA-resident director.

What is the difference between an SPV account and a traditional Irish property bank account?

SPV accounts offer multi-currency support, faster global payments, segregated accounts, and better reporting, while traditional property accounts are limited to basic rent and mortgage transactions.

Do Irish SPVs qualify for special tax treatment under Section 110?

Yes. SPVs holding qualifying assets and following arm’s-length practices may access Section 110 tax benefits, commonly used in securitisation and asset-holding structures.

Is Ireland a good location for SPVs in 2026?

Yes. Ireland offers strong legal protections, EU access, tax treaty benefits, and a mature SPV ecosystem, making it highly attractive for international investors.

Disclaimer: This content is for informational purposes only and is not intended as a recommendation or advisory service. Interpolitan Money does not offer advice on company formation, jurisdiction selection, or taxation. Professional guidance should be sought where needed.

 
 
 

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