London Banking Seminar

Tuesday, 10 May 2016

Welcome
Christine ODonovan
Partner & Head of Financial Services
Mason Hayes & Curran

Irish Property, Debt Holding

and Lending Structures
Conor Durkin, Partner
Mason Hayes & Curran
Robert Henson, Partner
Mason Hayes & Curran

Loan Origination Funds

Irish QIAIF
(ICAV)

SPV

Direct lending to
the economy

Qualifying Investor Alternative Investment

Fund (QIAIF)

QIAIF is an Irish regulated AIF

QIAIF can directly or indirectly grant loans

to borrowers

Distribution: QIAIF may be marketed in

EU under the AIFMD passport

CMU: major initiative to develop

alternatives to bank financing

Significant market opportunity shortage

of bank financing, lack of infrastructure
funding, political initiatives EIF and ISIF

Property Holding Structure - QIAIF

Irish QIAIF
(ICAV)
Irish Limited
Company
(General Partner)

Qualifying Investor Alternative

Investment Fund (QIAIF)

No Irish tax on QIAIFs income

or gains

Exit tax on payments to QIAIF

investors but exemption for nonresidents

QIAIF can hold a wide range of

assets, including real estate and
debt, either directly or through a
conduit vehicle

QIAIF can take different forms ICAV (new corporate entity) is

the most common new structure

100%

100% Limited
Partner

Irish Limited
Partnership

Irish Limited
Partnership

Irish Limited
Partnership

Asset

Asset

Asset

Unregulated Regime Section 110 Company

Normal Irish incorporated (or sometimes

non-Irish incorporated) limited liability
company which meets certain conditions
and elects into s.110 tax regime

Must be Irish tax resident

May only carry on business of holding

and/or managing qualifying assets and
activities ancillary to this

Qualifying assets include financial assets

such as shares and debt but not direct real
property interests

Taxable at 25% but ability to get deduction

for certain profit-dependent interest

Investors

S.110 SPV

Qualifying
Assets, e.g.
debts

The Future of NAMA

Frank Daly, Chairman
NAMA

Q&A
Michel Grace, Partner
Mason Hayes & Curran

Thank you
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