AVIATION FINANCE THE IRISH SECTION 110 REGIME

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1 AVIATION FINANCE THE IRISH SECTION 110 REGIME

2 Ireland - A Leading Aviation Jurisdiction Ireland is one of the leading locations in the world for all forms of aircraft finance and leasing activities. This is due to: Favourable tax environment including a 12.5% rate of corporation tax A long and successful tradition in the aviation industry Support of the Irish government and tax authorities Changes to the Irish tax legislation has enhanced the use of special purpose vehicles ( SPVs ) in aircraft finance, leasing and securitisation transactions

3 Key Benefits EU common law jurisdiction and OECD member Dedicated aviation debt listing platform on the Irish Stock Exchange Skilled service professionals experienced in aircraft finance and leasing transactions No Irish tax requirement for any profit/asset dependent fee to be kept in the SPV Ireland s Tax Benefits SPVs, when structured correctly, are effectively corporation tax neutralvehicles. Interest can be paid free of withholding tax on listed notes and wide exemptions also apply where the notes are not listed. SPVs can receive investment management services from abroad without incurring an Irish VAT liability. SPVs are tax resident in Ireland for the purposes of Ireland s double tax treaties and can avail generally of their benefits to receive income free of, or subject to a reduced, withholding tax from those jurisdictions. Ireland has signed in excess of 70 such treaties (see Schedule 1).

4 SPVs and Specific Irish Taxes Section 110 of the Irish Taxes Consolidation Act 1997 Section 110 permits an SPV s profits to be calculated as if it were carrying on a trade. Consequently, the cost of funding and related expenditure should be tax deductible. Section 110 also generally allows a payment of interest, the rate of which is dependent on the performance of the SPV, to be a tax deductible expense. While the SPV is liable to corporation tax at a rate of 25%, with careful structuring the SPV s taxable profit is generally maintained at a minimal level. There is no Irish minimum profit requirement for tax purposes Finance Act 2011 and Tax Deductibility The Irish Finance Act 2011 (the FA 2011 ) made certain amendments to Section 110. The definition of a qualifying asset has been extended to include commodities and plant and machinery. Previously, qualifying assets consisted of financial assets only, such as bonds, securities, shares, loans and derivatives. The FA 2011 also limited the ability for an SPV to obtain a full deduction for profit participating interest payments to investors in certain circumstances. These new rules seek to deny deductibility for that profit element unless:

5 (a) the payment of interest or other distribution is paid to an EU country or tax treaty partner country and is subject, without any reduction computed by reference to the amount of such interest or other distribution, to a tax which generally applies to profits, income or gains received in the receiving jurisdiction from sources outside that jurisdiction; or (b) Irish withholding tax has been deducted at the rate of 20% from the payment (this will typically occur where the payment is made to a recipient that is not resident in an EU Member State or a tax treaty partner country). These rules do not apply (so full deductibility is still allowed) where the recipient of the interest or other distribution is either a person resident in Ireland, or a person (resident in an EU Member State or tax treaty partner country who is not connected with the SPV) who is a pension fund, government body or other person who is exempted from tax which generally applies to profits, income or gains in that jurisdiction. The limitations are also disapplied (so full deductibility is still allowed) in respect of any payments made on quoted Eurobonds and wholesale debt instruments (discussed in more detail below) regardless of the location of the recipient, unless the recipient controls or is the main originator of assets for the SPV and the SPV is aware at the time the instruments are issued that the interest or other distributions to be paid would not satisfy the subject to tax test outlined at (a) above. Therefore, provided a distribution of profit is made in respect of a quoted Eurobond or a wholesale debt instrument, the payment should remain deductible as normal unless the recipient falls into a very narrow category and the SPV is aware of a double no-tax treatment applies to the payments it is making at the relevant time.

6 Section 110 Conditions In order for an SPV to avail of the beneficial provisions of Section 110 it must be a qualifying company. A qualifying company is defined as a company: (a) resident in Ireland; (b) which carries on a business of management and/or holding of qualifying assets including a business of leasing plant and machinery; (c) which, apart from activities ancillary to that business, carries on no other activities; (d) in relation to which the market value for qualifying assets on the day it first acquires assets is not less than 10 million; and (e) has notified the Irish Revenue Commissioners of its status within prescribed time limits. There is also a further limitation that an SPV will not be a Section 110 company if it carries on any transaction otherwise than by way of bargain made at arm s length apart from transactions or arrangements under which payments of interest or other distributions payable by the SPV do not represent a commercial rate of return or are dependent on the results of the SPV s business and are fully deductible as a tax expense. A qualifying asset is an asset of an originator which the SPV acquires or which is created by virtue of an arrangement entered into by the SPV with another person. An originator for these purposes is any government, public or local authority, company or other body corporate.

7 Tax Residency To fall within the Irish tax regime and benefit from Ireland s tax treaties, a company must be resident in Ireland for tax purposes. Tax residency is primarily determined by the central management and control test. Management and control relates to the decisions of fundamental importance to the business of the company as opposed to the day to day administration of the company. In practice, the board of directors should meet in Ireland and have some (preferably, a majority of) Irish resident directors on the board in order to achieve Irish tax residency. Ultimately, the residence of the company for tax purposes is a question of fact and it will, in each case, be necessary to demonstrate that the ongoing central management and control of the company is located in Ireland. Trading in Ireland An Irish tax resident company is subject to tax in Ireland on its worldwide profits and gains. The standard corporation tax rate applicable to trading income in Ireland is 12.5%. A higher rate of 25% is applicable to non-trading income ( passive income ). A rate of 33% applies to capital gains. Whether or not a company is considered to be trading is a question of fact which is ultimately a matter to be determined by the Irish courts. The Irish tax legislation does not define the terms trade or trading (though it does state that trade includes every trade, manufacture, adventure or concern in the nature of trade). As a result, it is necessary to consider relevant Irish case law and UK case law (which would not be binding on the Irish courts but would have persuasive value) as well as Irish Revenue practice.

8 The Irish Revenue s stated position is that trading presupposes that the company concerned is carrying on business activities from which it derives its income and that the activities will require people with appropriate skills and authority to carry out functions of the business (though the Irish Revenue accept that outsourcing of activities does not necessarily prevent a company s income being taxed as trading income). Generally trading means the carrying on of business or the engaging in activities on a regular basis with a view to realising a profit. In analysing whether a company is carrying on trade, it is important to demonstrate that the company has the necessary substance in Ireland. Tax Deductions An Irish trading company is entitled to deduct any revenue expenditure incurred wholly and exclusively for the purposes of the trade. Therefore, interest payments are generally tax deductible for an Irish trading company. Interest payments made to a non-eu 75% parent can be recharacterised as a non-deductible distribution. However, there is an exclusion from this recharacterisation where the interest is paid by a trading company to a treaty resident company and an election is made by the trading company. A lessor can also claim a tax deduction (referred to as capital allowances / tax depreciation ) in respect of capital expenditure incurred by it on the acquisition of aircraft (provided that the burden of wear and tear of the aircraft falls on the lessor). The rate of capital allowance available is 12.5% of the capital expenditure on a straight line basis over a period of eight years.

9 The financing expenses and other general trading expenses should generally further reduce the effective tax rate of the Irish owner or lessor substantially. In the case of lease in/lease out structures, where a foreign lessor leases through an Irish company to a foreign lessee, generally the Irish company will only be taxed on the margin it earns. Extraction of Profits A central component of Ireland s tax policy is to facilitate international investment. This means that there are a wide range of exemptions from Irish withholding tax on dividends and interest paid by an Irish company and in respect of capital gains realised by a foreign shareholder on a disposal of Irish shares. In particular, dividends and interest paid to a company resident in an EU jurisdiction or tax treaty partner country should generally be exempt from Irish withholding taxes.

10 Other Irish Taxes Withholding Tax Basic rule Subject to a number of wide ranging domestic exemptions (and exemptions contained in tax treaties) an Irish resident company must operate a 20% withholding tax on all payments of annual interest. There are a number of exemptions from this withholding obligation relevant to Section 110 SPVs. Careful attention must be paid to the interaction and application of these exemptions with the FA 2011 provisions regarding possible restrictions on the tax deductibility of payments made by the Section 110 SPV. Quoted Eurobond exemption In the context of an aircraft financing SPV or an SPV engaged in the securitisation of an aircraft portfolio, the exemption normally availed of is the quoted Eurobond exemption. In order to avail of this exemption the interest must be paid on a quoted Eurobond which is a security which: (a) is issued by a company; (b) is quoted on a recognised stock exchange; (c) is in registered or bearer form; and (d) is cleared through a recognised clearing system or payments are made through a paying agent located outside Ireland.

11 For these purposes a recognised clearing system includes Euroclear, Clearstream and the Depository Trust Company. Once the relevant conditions are satisfied, interest on the bonds can be paid free of withholding tax regardless of the tax resident status of the holder. This is the main reason why this exemption is utilised where there is a broad profile of investors in any specific transaction. EU/Double tax treaty countries An Irish domestic exemption permits payments of interest by a Section 110 SPV to a person resident in a country with which Ireland has a double tax treaty (such as the US, China, Hong Kong, Singapore) or in a member state of the EU (other than Ireland) to be made free of withholding tax. There is no specific documentary evidence that must be received by the SPV to establish where the beneficial owner is resident but it is normal to put in place some mechanism under which the SPV could obtain a confirmation from the beneficial owners of their status and to ensure that if there is a transfer of the right to receive interest the transferee provides the same level of comfort. Double tax treaty relief Similarly, under double taxation treaties entered into between Ireland and other countries it may be possible for a reduction in or an exemption from withholding tax to be claimed. This would require formal claims to be made under the relevant treaty. These treaties are also obviously relevant in the context of the SPV receiving income (lease rentals and interest) free of withholding tax as well as being able to make payments free of withholding tax to its investors.

12 Tax treaties play a vital role in Ireland s successful aircraft leasing industry by reducing or eliminating withholding taxes on inbound lease rental payments. Tax treaties allow Irish lessors to claim tax credits against their Irish corporation tax for any unrelieved foreign withholding taxes. Due to recent legislative changes, an Irish lessor carrying on a trade in Ireland may now also claim a tax credit for foreign withholding taxes on lease rentals where there is no applicable tax treaty. The relief is granted on a unilateral basis by Irish domestic law. This legislative change has increased Ireland s attractiveness as a leasing jurisdiction for owing and leasing aircraft and other assets into jurisdictions which do not have an extensive tax treaty network. VAT From 1 January 2010 leasing services supplied by an Irish established lessor to a non-eu established lessee, or a business lessee established in another EU Member State, are outside the scope of Irish VAT. The Irish lessor will not charge VAT on the lease rentals and should be entitled to a refund in respect of any Irish VAT incurred. Leasing services supplied to an Irish established lessee will be subject to Irish VAT. Where the lessor is established outside of Ireland, the Irish lessee must self account for the VAT arising. The Irish lessee will be required to register for VAT in Ireland and make a VAT return to the Irish Revenue Commissioners. The Irish lessee will be entitled to claim a deduction for the VAT arising to it. This VAT accountability should not therefore result in an absolute cost for the Irish established lessee.

13 Stamp Duty Any instrument that documents the purchase of title to an aircraft or part of an aircraft or an interest in an aircraft is not liable to Irish stamp duty. Accounting Treatment As an SPV is taxed as if it were carrying on a trade the tax treatment normally follows the accounting treatment. If profits arise under accounting principles these would normally be subject to corporation tax at a rate of 25%. If structured correctly, there should be minimal taxable profits.

14 CONTACT US Martin Phelan T: E: David Maughan T: E:

15 SCHEDULE 1 Ireland s Network of Double Taxation Treaties Albania Armenia Australia Austria Bahrain Belarus Belgium Bosnia & Herzegovina Bulgaria Canada Chile China Croatia Cyprus Czech Republic Denmark Egypt Estonia Finland France Georgia Germany Greece Hong Kong Hungary Iceland India Israel Italy Japan Korea (Republic of) Kuwait Latvia Lithuania Luxembourg Macedonia Malaysia Malta Mexico Moldova Montenegro Morocco Netherlands New Zealand Norway Pakistan Poland Portugal Romania Russia Saudi Arabia Serbia Singapore Slovak Republic Slovenia South Africa Spain Sweden Switzerland Thailand Turkey United Arab Emirates Ukraine United Kingdom United States of America Uzbekistan Vietnam Zambia

16 DUBLIN LONDON NEW YORK SILICON VALLEY Tel: williamfry.com William Fry. All rights reserved. (AVI0715)

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