Set Up an SPV and Open a Business Bank Account in Ireland

Ireland is a leading EU base for Special Purpose Vehicles (SPVs), used for securitisation, aircraft leasing, loan portfolios, acquisitions and investment holding, often by owners based outside Ireland.

Section 110 of the Taxes Consolidation Act 1997 gives qualifying financing and securitisation vehicles a tax-neutral regime, and Ireland's euro-area membership and common-law courts make it a familiar choice for international investors, corporate groups, private equity firms and transaction sponsors.

Incorporation takes place through the Companies Registration Office (CRO), which aims to process correctly submitted ordinary online applications within ten working days. Once the CRO has issued the company number, the SPV needs an account in its own name to take in capital, pay advisers and complete the transaction. For owners outside Ireland, that account usually takes more preparation than the Form A1 filing, because the provider has to check every layer of ownership against the RBO entry.

This guide explains both sides of the process:

• How to set up an SPV in Ireland
• The principal Irish SPV structures, including LTDs and DACs
• How Section 110 companies work
• Irish share capital and EEA-resident director requirements
• CRO incorporation and beneficial ownership registration
• Incorporation timelines and costs
• Tax and ongoing reporting requirements
• How to open a business account for an Irish SPV
• Foreign ownership and non-resident directors
• What account providers assess and which documents they require
• Multi-currency accounts and international payments

Irish SPV at a Glance

What Is an SPV in Ireland?

An Irish Special Purpose Vehicle (SPV) is a company formed for a defined purpose, such as securitisation, structured finance, an acquisition, investment holding, a joint venture or aircraft leasing.

It is not a separate legal form. Irish SPVs commonly use an LTD or DAC, while qualifying financial-asset vehicles may also use the Section 110 tax regime.

Is an SPV Just a Limited Company?

In Ireland, usually yes. An SPV is commonly an ordinary LTD or DAC established for a particular investment or transaction.

Unlike an operating company with customers and recurring trading income, it may exist to hold a single asset or complete one transaction.

Its separate legal personality keeps the company's assets and liabilities generally distinct from those of its shareholders.

Why Set Up an SPV in Ireland?

Ireland combines EU membership, a common-law legal system and a specific tax regime for financing vehicles under Section 110. Dublin's international financial services sector also gives sponsors access to administrators, trustees and law firms used to securitisation, aircraft leasing and cross-border acquisitions.

Competitive Corporate Tax and Section 110 Framework

Ireland's 12.5% Corporation Tax rate on qualifying trading income has helped establish its reputation as an attractive location for international business. Non-trading investment income is generally taxed at 25%, while the dedicated Section 110 regime provides specialist tax treatment for qualifying securitisation and financial-asset vehicles, subject to eligibility requirements.

Straightforward Incorporation

An Irish LTD can be incorporated through the Companies Registration Office (CRO) without a mandatory notarial incorporation step or pre-incorporation share-capital deposit. It can have one director, although a separate company secretary and compliance with the EEA-resident director requirement are necessary.

Flexible Corporate Structures and Limited Liability

Ireland offers LTDs for investment holding, acquisitions and joint ventures, alongside Designated Activity Companies (DACs) for transactions requiring defined corporate activities. Both provide separate legal personality, generally separating the SPV's assets and liabilities from those of its shareholders.

EU Membership and Euro Payments

Ireland provides an EU base for international investors and access to the European single market. Its membership of the euro area and participation in SEPA support euro-denominated payments and transactions with European counterparties.

Extensive Double Tax Treaty Network

As of February 2026, Ireland has signed double taxation agreements with 78 countries, with 75 in effect. For an Irish SPV, treaty relief matters most on interest and dividends paid to overseas lenders and investors, where it can reduce Irish withholding tax, subject to each treaty's conditions.

Established Banking and Financial Services Sector

Dublin is home to many of the administrators, corporate services providers, trustees and law firms that run Section 110 and aircraft-leasing vehicles, and Euronext Dublin is a common listing venue for the notes these SPVs issue.

Ireland suits financing, securitisation, leasing and acquisition SPVs best where the assets, investors or payments are European, provided the EEA-resident director rule, the €10 million Section 110 threshold and the 25% rate on non-trading income are planned for before incorporation.

What Types of SPV Can Be Set Up in Ireland?

Irish SPVs are generally established as private limited companies, with the choice of legal structure depending on the assets held, the intended transaction and the requirements of investors and lenders.

The two principal corporate options are an LTD and a Designated Activity Company (DAC). Both provide separate legal personality and limited liability, but differ in how their activities are defined and how they are managed.

Private Company Limited by Shares (LTD)

An LTD is the most common SPV form and a flexible option for Irish SPVs holding investments, acquiring businesses or assets, and undertaking joint ventures.

It has a single-document constitution without an objects clause, giving the company broad capacity to carry on lawful activities, although it cannot operate as a credit institution or insurance undertaking. This can suit an investment or acquisition vehicle whose transactions may develop over time.

An LTD can have one shareholder and one director, although a sole director must appoint a separate company secretary. Shareholders' liability is generally limited to any amount unpaid on their shares.

For an acquisition or holding SPV that does not need Section 110 status, an LTD is usually the simplest choice, as it needs only one director and one shareholder.

Designated Activity Company (DAC)

A DAC is a private company whose constitution specifies the activities for which it has been established.

This makes it particularly relevant for structured finance, securitisation and other transactions in which investors, lenders or counterparties want the SPV's intended purpose formally documented.

A DAC has a memorandum and articles of association, and requires at least two directors. A DAC limited by shares provides separate legal personality and generally limits shareholders' liability to any amount unpaid on their shares.

The more defined constitutional purpose can be useful where a financing arrangement is designed around specified assets, obligations or payments.

An LTD or DAC can also be considered for Section 110 treatment if the company meets the separate tax conditions. Section 110 is not a third company type.

The choice usually comes down to whether lenders or noteholders need the SPV's activities fixed in its constitution, which points to a DAC, and whether it will qualify for Section 110. Regulated fund vehicles such as ICAVs are outside the scope of this guide, and Irish legal and tax advice should be taken before incorporating.

What Is a Section 110 Company?

A Section 110 company is an Irish tax-resident company that qualifies for a specialist tax regime under Section 110 of the Taxes Consolidation Act 1997. It is widely used for securitisation, structured finance, loan portfolios, leasing, collateralised loan obligations (CLOs) and commercial or residential mortgage-backed securities (CMBS and RMBS).

The regime allows qualifying companies to structure financing arrangements efficiently, making it an important part of Ireland's international financial-services sector.

Section 110 is not a separate legal structure. An Irish LTD or DAC can qualify for the regime if it meets the relevant conditions.

Qualifying Conditions

To qualify under Section 110, an Irish company must:

• Be tax-resident in Ireland.
• Acquire, hold or create qualifying assets, such as loans, securities, receivables, certain leasing assets and commodities traded on a recognised commodity exchange.
• Carry on the business of holding or managing those assets in Ireland.
• Restrict its activities to that business and related activities.
• Hold qualifying assets worth at least €10 million when it first acquires, holds or creates them.
• Notify Revenue using Form S.110 within eight weeks of meeting the relevant qualifying-asset condition.
• Meet the applicable arm's-length transaction requirements.

The €10 million threshold applies when the qualifying assets are first acquired, held or created. It is not a minimum balance that must be maintained throughout the company's life.

Irish tax residence and genuine business activity are also important. Revenue does not generally expect a Section 110 company to be treated as resident elsewhere where its directors act independently in Ireland and do not take instructions from third parties. A purely passive activity is unlikely to count as a business, although active management outsourced to an appropriate manager is acceptable. Simply incorporating an Irish company and placing assets into it does not automatically establish Section 110 eligibility.

Tax Treatment and Funding Limits

Section 110 was designed to provide tax-neutral treatment for qualifying securitisation transactions, as set out in Revenue's guidance last updated in August 2026.

Qualifying companies generally pay Corporation Tax at 25% on taxable profits, but calculate those profits using Case I rules, allowing certain financing costs and expenses to be deducted.

A common financing arrangement involves profit-participating notes (PPNs), where interest payments are linked to the performance of the underlying assets. These can help match the company's income with its financing obligations.

However, since Finance Act 2019, restrictions apply to interest deductions involving certain connected parties, known as specified persons, and assets linked to Irish property. CLO, CMBS and RMBS, loan origination and sub-participation transactions have specific exceptions.

Some securitisation vehicles also use orphan structures, with shares held by a trustee to support separation from the transaction sponsor. These arrangements must have a genuine commercial purpose.

Do You Need Section 110 Status?

No. Most straightforward Irish acquisition, investment-holding and joint venture SPVs do not need Section 110 status.

It is primarily relevant where the SPV holds substantial qualifying financial assets and requires a specialist securitisation or structured-finance arrangement.

For example, an Irish company established to acquire a business would not ordinarily require Section 110 status. A financing vehicle acquiring a substantial loan portfolio may benefit from it if the conditions are satisfied.

The choice should be made before the transaction is structured, with specialist Irish tax advice.

How to Set Up an SPV in Ireland

Establishing an Irish SPV generally involves six steps, from defining its purpose and ownership to registering the company with the Companies Registration Office (CRO) and completing the relevant tax and beneficial ownership requirements.

The exact process depends on whether the SPV is an ordinary LTD or DAC, or also intends to qualify under Section 110.

Step 1: Define the Purpose and Map the Ownership

Before incorporation, the parties should establish:

• What assets the SPV will hold or acquire
• What transaction it will undertake
• Who will own and control the company
• Where its investment capital will originate
• How it will be funded, including shareholder loans or financing
• Which countries, counterparties and currencies will be involved
• How funds will enter and leave the structure
• Whether Section 110 treatment is required

For an international investment structure, ownership might look like this:

Individual Investor

↓

International Holding Company

↓

Irish SPV

↓

Underlying Investment or Asset

Each ownership layer should have a clear commercial purpose, particularly where international investors or holding companies are involved. This information will also be important when opening the SPV's business account.

Step 2: Meet the EEA Director Rule and Appoint Officers

An Irish LTD requires at least one director, while a DAC requires two. Both must appoint a company secretary, and a sole LTD director cannot also serve as secretary.

Irish companies must generally have at least one director resident in the European Economic Area (EEA), and failing to meet this requirement is a criminal offence.

Where no EEA-resident director is appointed, the company can instead obtain a prescribed €25,000 Section 137 bond from a bank, building society, insurer or credit institution, valid for at least two years.

An incorporated company may also obtain a Certificate of real and continuous link to economic activity in Ireland, providing an exemption from the residency requirement.

Step 3: Secure a Registered Office and Prepare the Constitution

The SPV must have a registered office at a physical address in Ireland. An authorised corporate-services provider can supply this address.

The company must also prepare its constitution:

• LTD: A single-document constitution without an objects clause.
• DAC: A memorandum and articles specifying the company's permitted activities.

The proposed company name, shareholders, share capital and principal business activity must also be established.

Step 4: Register with the CRO

The incorporation application is submitted through the CRO's CORE system using Form A1 and the company constitution.

Form A1 includes the directors, secretary, shareholders, registered office and intended activity in Ireland, together with the appropriate NACE activity code. Where a Section 137 bond is used, the bond box on Form A1 must be ticked, and these applications cannot be prioritised.

Online incorporation costs €50. The CRO aims to issue a Certificate of Incorporation within ten working days for a correctly submitted ordinary online application. A five-working-day scheme is available through qualifying Fé Phráinn participants.

The certificate confirms the company's registration and provides its company number.

Step 5: Register Beneficial Ownership

Following incorporation, the SPV must register its ultimate beneficial owners with Ireland's Central Register of Beneficial Ownership (RBO) within five months.

This includes identifying the individuals who ultimately own or control the company, including through overseas holding companies. Access to the register is tiered, with competent authorities, designated persons and the public each able to see different levels of detail.

Beneficial owners without an Irish Personal Public Service Number (PPSN) must complete the applicable identity-verification process to obtain an identification number for the RBO filing.

Step 6: Complete Revenue and Central Bank Registrations

The company must complete its applicable Irish tax registrations with Revenue once its CRO registration number has been issued.

For a qualifying Section 110 company, additional requirements apply:

• Revenue: Submit Form S.110 within eight weeks of meeting the relevant qualifying conditions.
• Central Bank of Ireland: Relevant Section 110 SPVs must notify the Central Bank within five working days of their first financial transactions and meet the applicable statistical reporting requirements.

Section 110 companies already reporting as financial vehicle corporations follow a separate Central Bank reporting framework.

The overall establishment timeline depends on the ownership structure, directors, incorporation documentation and any specialist tax or regulatory requirements. Banking arrangements should also be planned early, particularly where the SPV will receive substantial international investment capital.

What Documents Are Needed to Set Up an Irish SPV?

Requirements depend on the company type and ownership structure, but establishing an Irish SPV as an LTD or DAC generally involves preparing the following information and documents:

• Proposed company name and optional CRO name-reservation confirmation.
• Physical registered office address in Ireland and company email address.
• Company constitution: one document for an LTD, or memorandum and articles for a DAC.
• Form A1, including the intended activity in Ireland and relevant NACE code.
• Director and company secretary details, addresses and consent to act.
• Subscriber details, shareholdings and share capital arrangements.
• Shareholder identities and corporate registration details for overseas shareholders, where relevant.
• Evidence of an EEA-resident director or a prescribed Section 137 bond where required.
• Ultimate beneficial owner details and the ownership structure, including overseas holding companies.
• PPSN or identification number obtained through Form VIF for beneficial owners who do not have a PPSN.
• Statutory incorporation declarations and signatures required for the CRO submission.
• After incorporation, beneficial ownership information for filing with the RBO.
• For Section 110 companies, Form S.110 for Revenue and the applicable Central Bank notification information.

Form A1 and the constitution are submitted to the Companies Registration Office through CORE. The RBO and Section 110 notifications are separate post-incorporation requirements, not documents needed to register an ordinary LTD.

Once the CRO issues the Certificate of Incorporation and company number, the five-month RBO deadline starts, so owners without a PPSN should begin the Form VIF process early to avoid delaying the filing.

How Much Does It Cost to Set Up an SPV in Ireland?

The cost of establishing an Irish SPV depends on its legal structure, ownership arrangements and the professional services required for the transaction.

For an LTD or DAC, the principal statutory charges and other possible costs are:

The €25,000 Section 137 bond represents the required financial cover, not the premium paid to obtain it. The €20 annual return fee is an ongoing filing cost rather than an incorporation expense.

Costs for Institutional and Investment SPVs

The €50 CRO fee is a small part of the budget. A Section 110 or institutional SPV will usually also pay for Irish legal and tax advice, a corporate services provider and registered office, an EEA-resident director or Section 137 bond, an audit, Central Bank reporting and, for securitisations, a trustee and note documentation.

What Are the Tax Considerations for an Irish SPV?

Ireland offers an established corporate tax framework for international investment and financing structures. However, the tax treatment of an Irish SPV depends on its activities, underlying assets, financing arrangements and whether it qualifies for a specialist regime such as Section 110.

Corporation Tax

Ireland applies different Corporation Tax rates depending on the income generated by the SPV:

• Trading income: Qualifying trading profits are generally taxed at 12.5%.
• Non-trading income: Passive investment income, rental income and other non-trading profits are generally taxed at 25%.
• Section 110 companies: Qualifying securitisation and financial-asset vehicles generally pay 25% Corporation Tax on taxable profits calculated under Case I rules, with specific deductions for eligible financing costs.
• Dividend income: Dividends received from other Irish companies are generally exempt from Corporation Tax. Since January 2025, qualifying dividends from overseas subsidiaries can also benefit from Ireland's participation exemption, which the Finance Act 2025 expanded.
• Capital gains: Irish companies disposing of investments or other assets can be subject to tax at rates equivalent to Capital Gains Tax, generally 31% for disposals from 7 October 2026. Qualifying disposals of shares in certain trading companies can benefit from an exemption under Section 626B.
• Tax returns and payments: Corporation Tax returns and outstanding balances are generally due by the 23rd of the ninth month following the accounting period, with preliminary tax payments subject to separate deadlines. Late filing triggers a surcharge of 5% of the tax due, capped at €12,695, where the return is filed within two months of the deadline, or 10%, capped at €63,485, after that.

The key distinction is that Ireland's 12.5% trading rate does not automatically apply to an SPV simply because it is incorporated in Ireland.

Withholding Tax, Dividends and Treaties

Ireland has an extensive double taxation treaty network and several exemptions relevant to international corporate structures.

• Dividend withholding tax: Irish companies generally deduct 25% from dividend payments. Qualifying non-resident shareholders can receive dividends without this deduction where the relevant exemption conditions and declarations are satisfied.
• Interest withholding tax: Certain annual interest payments are generally subject to 20% withholding tax, although exemptions may apply, including for qualifying quoted Eurobonds and eligible international financing arrangements.
• Double taxation agreements: Ireland has signed treaties with 78 countries, with 75 in effect. These can reduce withholding taxes and provide relief from double taxation on qualifying cross-border income.
• International investment structures: The tax treatment of dividends, shareholder loans and financing payments depends on the recipient's jurisdiction, ownership arrangements and applicable exemptions.

For an internationally funded SPV, withholding taxes can materially affect financing costs and the amount available for distributions to investors.

VAT and Pillar Two

Ireland's standard Value Added Tax (VAT) rate is 23%. Compulsory registration generally applies above €42,500 in annual taxable services turnover or €85,000 for qualifying goods businesses.

However, many financial and investment activities are VAT-exempt. A passive holding company that simply owns shares may have no entitlement to recover VAT on its expenses, even where substantial professional fees are incurred.

Ireland also applies the OECD Pillar Two framework, introducing a 15% minimum effective tax rate for multinational and large domestic groups generally meeting the €750 million consolidated annual revenue threshold in at least two of the preceding four years.

Property-Holding SPVs

Irish SPVs holding property can face additional tax considerations.

Rental income is generally taxed at the 25% non-trading Corporation Tax rate. Certain closely held companies can also face a 20% surcharge on undistributed after-tax rental and investment income where the relevant amounts are not distributed within 18 months.

Property acquisitions may attract Stamp Duty, including a standard 7.5% rate on non-residential property transfers. The tax treatment of residential property differs.

Section 110 also contains restrictions on certain financing deductions involving Irish property-related assets, making the choice of structure particularly important.

The SPV label does not decide the tax result. In Ireland the main questions are whether profits are trading income at 12.5% or non-trading income at 25%, whether the SPV qualifies for Section 110, and whether the close company surcharge or Irish property rules apply, so take Irish tax advice before the structure is set.

What Are the Ongoing Reporting Requirements?

Irish SPVs have ongoing company, tax and beneficial-ownership reporting obligations. For institutional and financing structures, additional requirements can apply depending on the assets held and whether the company qualifies under Section 110.

For an Irish LTD or DAC used as an SPV, the principal obligations are:

Late CRO annual returns attract a €100 penalty plus €3 per day, capped at €1,200 per return. Late filing can also affect eligibility for audit exemption.

A holding SPV mainly deals with the CRO annual return, Revenue and the RBO, while a Section 110 vehicle adds Form S.110, quarterly Central Bank returns and often an audit, so the budget and service providers should reflect which of these applies.

Opening a Business Bank Account for an Irish SPV

Ireland is one of Europe's established international financial centres, with a substantial banking, investment funds and financial services industry. As a member of the European Union and eurozone, it offers access to euro-denominated business accounts and the Single Euro Payments Area (SEPA), supporting payments across Europe.

Businesses in Ireland can access traditional banks, digital banking providers and specialist payment institutions offering international accounts, multicurrency services and cross-border payments. However, providers differ in their eligibility requirements, account capabilities and the types of businesses they support.

For Irish SPVs, choosing the right provider is particularly important. While Ireland is a major centre for international investment and financing structures, some banks may be reluctant to support non-trading SPVs, foreign shareholders, overseas directors or complex institutional ownership arrangements. Specialist account providers familiar with these structures may offer more suitable solutions, depending on the SPV's activities and banking requirements.

Once the CRO has issued the company number, the account is usually the next step. Unlike a trading company with customers and regular revenue, an Irish SPV might receive capital from overseas investors or a foreign holding company, hold a loan portfolio or shares, and make a few large payments rather than many small ones. None of this rules out an account, but the provider will check the ownership against the RBO entry and want to see where the money comes from and how the account will be used.

Can an Irish SPV Open a Business Bank Account?

Yes. An Irish SPV can open a business bank account. Approval depends on the company's structure, ownership, purpose, funding and expected activity, as well as the provider's requirements.

For an Irish SPV, account providers will typically assess:

• Company structure: Whether the SPV is an Irish LTD, DAC or another type of company.
• Business purpose: Why the SPV was established and the investment, acquisition or financing activity it will undertake.
• Ownership: The shareholders, Ultimate Beneficial Owners (UBOs) and any overseas companies or institutional investors involved.
• Irish registration: The company's CRO details, directors and beneficial ownership information.
• Source of funds: Where the money entering the SPV will come from, including investors, shareholders or lenders.
• Source of wealth: How the owners or investors obtained their wealth, where relevant.
• Underlying assets: The investments, shares, loans or other assets the SPV will hold.
• Account activity: Expected balances, payment amounts, frequency and counterparties.
• International payments: The countries and currencies involved in receiving and making payments.
• Supporting documents: Relevant investment, acquisition or financing agreements. Section 110 companies may also need additional documentation relating to their structure.

A newly incorporated Irish SPV can apply without any trading history. Providers look instead at the CRO certificate, constitution, RBO entry and deal documents, and for a Section 110 company the Form S.110 notification, alongside the ownership, source of funds and expected transactions.

Can Foreign Owners and Non-Resident Directors Open an Irish SPV Business Account?

Yes. An Irish SPV can be owned by foreign individuals, investment funds or international companies, and can open a business account with non-resident shareholders and directors, including those based outside the European Union.

However, Ireland has an important company-law requirement. An Irish company must normally have at least one director resident in the European Economic Area (EEA). If all directors live outside the EEA, the company can generally satisfy this requirement through a Section 137 bond providing €25,000 of cover. Qualifying companies may also obtain an exemption by demonstrating a real and continuous link with economic activity in Ireland.

Importantly, this is a company incorporation requirement, not a general requirement for opening an Irish business account. Account providers assess directors, shareholders and authorised users separately. Specialist providers may support businesses with entirely non-resident directors and shareholders, including those based in the US, UK and other non-EEA countries.

For example, an international investment structure might look like this:

US-Based Ultimate Beneficial Owner

↓

Delaware Holding Company

↓

Irish SPV

↓

European Loan Portfolio

The account provider will typically assess:

• Who ultimately owns and controls the US holding company and Irish SPV
• Why the Irish SPV has been established and what assets it will hold
• Where the investment funding originates
• How funds will move between the US, Ireland and other countries
• What currencies, payments and distributions are expected
• Who will operate the account and where they are based
• Whether the company's CRO and beneficial ownership records match the structure provided

Ireland also requires beneficial ownership information to be recorded with the Register of Beneficial Ownership (RBO). Where a beneficial owner does not have an Irish Personal Public Service Number (PPSN), an alternative identification number can be obtained through Form VIF.

Overseas owners and directors are not a barrier on their own. The provider will check that the ownership chart, the RBO entry and the people signing on the account all match, and that the EEA director rule has been met through a director, a Section 137 bond or a Certificate of real and continuous link.

Specialist providers such as Banq Global can offer Irish business accounts to eligible companies with non-resident directors and shareholders, including international structures with ownership outside Europe. Through its financial partners, Banq Global can also support qualifying foreign-incorporated businesses, such as US companies, seeking Irish account details without necessarily incorporating a separate Irish company. All applications remain subject to eligibility and compliance approval.

What Will an Account Provider Want to Understand?

Irish banks and specialist account providers must carry out customer due diligence under Ireland's anti-money laundering requirements. For an SPV, this generally comes down to four key questions:

1. Who owns and controls the Irish SPV?

The provider will verify the shareholders, Ultimate Beneficial Owners (UBOs) and ownership structure, including any overseas holding companies or institutional investors. It will also review the company's CRO details and beneficial ownership information registered with Ireland's RBO.

2. Why was the Irish SPV established?

The company must have a clear commercial purpose, whether it is being used to hold investments, acquire a business, manage financial assets or undertake a Section 110 financing transaction. Relevant investment or acquisition agreements can help explain its activities.

3. Where will the investment capital come from?

The provider will assess the source of funds and, where relevant, the source of wealth. This may include shareholder contributions, international investor capital, institutional financing or loans. Supporting documents should explain where the money originates and how it will be used.

4. How will the Irish business account operate?

Providers will assess expected balances, currencies, countries, payment amounts and the movement of funds. For example, an Irish SPV receiving USD investment capital from American investors and making large EUR acquisition payments has different requirements from an SPV receiving regular investment distributions.

A well-prepared Irish SPV application should explain these four areas clearly, supported by company records, ownership information and relevant transaction documents.

Top Business Account Providers for Irish SPVs

Irish SPVs can access different types of business account providers, including traditional banks, digital providers and specialist financial services firms. The right choice depends on the SPV's ownership, investment activities and banking requirements.

For a straightforward Irish SPV with local ownership, a traditional bank may be suitable. However, an institutional investment or financing SPV with international shareholders, complex ownership or substantial cross-border transactions may benefit from a specialist provider.

Before choosing a provider, consider:

• Whether it accepts SPVs, foreign shareholders and non-resident directors
• Whether it offers Irish account details and the currencies required
• Whether it supports the expected transaction values and international payments
• Account fees, foreign exchange costs and ongoing support
• How client funds are held and protected

Not every digital provider supports SPVs. For example, Revolut's Irish business terms identify SPVs among the structures it may be unable to accept.

The most suitable provider is therefore not necessarily the largest bank or the cheapest digital service, but one that understands the SPV's structure and can support its intended activities.

What Documents Are Needed to Open an Irish SPV Business Account?

Depending on the account provider, ownership structure and intended transactions, an Irish SPV may be asked for:

• CRO Certificate of Incorporation
• Company constitution (LTD or DAC, as applicable)
• CRO registration number and company extract
• Register of members or shareholders
• Corporate ownership chart showing overseas holding companies
• Director, company secretary and authorised signatory details
• Ultimate Beneficial Owner (UBO) details and internal beneficial ownership register, consistent with the RBO filing
• Passport copies and proof of residential address
• Irish registered office address
• Incorporation documents for overseas corporate shareholders
• Evidence of the source of investment funds
• Source of wealth evidence, where required
• Investment or acquisition agreements
• Shareholder loan and financing agreements
• Underlying investment or asset documentation
• Investor commitments or shareholder funding records
• SPV business plan or transaction overview
• Expected account balances, currencies and payment volumes
• Anticipated flow of funds, including countries and counterparties
• For Section 110 companies, relevant financing documents and the Form S.110 notification, where already submitted

For a new SPV, providers focus on the deal and the owners rather than past trading, so the purchase, loan or subscription agreements and an ownership chart that matches the RBO entry matter most. Where a corporate shareholder sits outside Ireland, expect to provide certified copies of its registration documents.

Multi-Currency and International Payments

Ireland's position in the eurozone gives Irish SPVs access to the Single Euro Payments Area (SEPA), allowing euro payments across participating European countries. For investment and financing vehicles operating internationally, however, euro payments are often only part of their banking requirements.

An Irish SPV can receive, hold and transfer multiple currencies, depending on its account provider. Common requirements include:

• A business account with an Irish IBAN in the SPV's name
• SEPA transfers for domestic and cross-border EUR payments
• SWIFT payments to and from countries outside SEPA, where supported
• GBP payments through UK payment networks, where available
• Receiving and holding EUR, USD and GBP balances
• Foreign exchange for international investments and financing
• Capital contributions from overseas shareholders and investors
• Shareholder loans and other financing payments
• Acquisition and investment payments to international counterparties
• Dividends, interest and distributions to investors
• Payments to fund administrators, legal advisers and other service providers

For example, an Irish aircraft-leasing SPV may receive lease rentals in USD from an airline, pay Irish advisers in EUR and distribute returns to investors in GBP.

Specialist providers such as Banq Global can arrange Irish business account details in the company's name, alongside multi-currency accounts, foreign exchange and international payments through their financial partners, subject to eligibility and the services available.

The important distinction is that an Irish IBAN does not automatically mean every currency or payment network is supported. Providers may differ in their payment limits, settlement arrangements, foreign exchange charges and ability to process large or frequent transfers.

A Section 110 vehicle collecting loan repayments every month and paying noteholders quarterly has a very different account profile from an acquisition SPV making one payment at completion, so set out the expected currencies, amounts and counterparties at onboarding.

Should You Arrange the Business Account Before or After Incorporating an Irish SPV?

For an Irish LTD or DAC, the business account is generally opened after incorporation, although banking preparation should begin earlier.

Unlike in Luxembourg, Irish company incorporation does not normally require a pre-incorporation share-capital deposit or a capital-blocking certificate for these structures, and there is no notary step. Each subscriber takes at least one share, and an LTD need not state a fixed authorised capital. The CRO requires Form A1 and a company constitution, submitted through CORE.

Once registered, the SPV receives a Certificate of Incorporation and company number, which account providers will normally request. Beneficial ownership details must also be established before the account is used for transactions.

In practice the order is CRO registration and then the account, but the application can be prepared while the Form A1 is with the CRO. Where a Section 110 company must notify the Central Bank within five working days of its first transaction, or the RBO filing depends on a non-resident owner getting a VIF number, preparing the ownership documents, source of funds and expected payments at the same time helps keep completion on track.

How Banq Global Supports Irish SPVs

Banq Global is a specialist provider of business account solutions for SPVs, including institutional investment vehicles and complex international structures. Companies should generally have an annual turnover of at least £1 million. However, parent company or wider group turnover may also be considered when assessing eligibility. We are not a bank; we work with financial partners to provide suitable business accounts and payment solutions.

Our Irish business account solution offers a dedicated Irish IBAN in the company's name, online onboarding and support for eligible non-resident directors, international shareholders and institutional ownership structures.

Our services include:

• Irish EUR business accounts with a dedicated IE IBAN
• Accounts opened in the SPV's legal name
• Support for non-resident directors and international UBOs
• Support for complex and multi-entity ownership structures
• EUR, USD, GBP and multi-currency accounts
• SEPA, SWIFT and other supported payment networks
• Foreign exchange and international transfers
• Investment funding, shareholder loans and acquisition payments
• Investor distributions and professional fees
• Local business accounts in 20+ countries, where eligible
• One online platform and a dedicated account manager

For institutional SPVs, the challenge is often not simply opening an account, but finding a provider that understands the structure, the transaction and how funds need to move. Banq Global helps bring these requirements together, coordinating with its financial partners to make the banking process simpler for investors, advisers and the teams managing the SPV.

Our Process

1. Check Your Eligibility

Tell us about your Irish SPV, ownership structure and business-account requirements.

2. Work With Your Dedicated Account Manager

We review your structure, documents, funding and expected transactions, and coordinate onboarding with our financial partners.

3. Start Using Your Business Account

Once approved, access your Irish account details, supported currencies and international payment services. SPV onboarding can take as little as five days with complete documentation, with account activation possible within 24 hours of approval. Timings depend on the application.

We bring together the account, payment and currency requirements of your Irish SPV through one specialist relationship, even where the structure is complex or international.

Is Ireland the Right Jurisdiction for Your SPV?

Ireland can be a strong choice for international investors setting up securitisation, structured finance, aircraft leasing and investment-holding SPVs, particularly where the assets, investors or payments are European or the vehicle can qualify for Section 110.

However, these benefits should be weighed against the EEA-resident director rule or the cost of a Section 137 bond, the €10 million qualifying-asset threshold and Central Bank reporting for Section 110 companies, the limits on Irish property assets, and the 25% Corporation Tax rate on non-trading income.

Where the assets and investors sit mainly in the UK or the US, another jurisdiction such as the UK or Luxembourg may suit the structure better. The final choice should come down to the SPV's purpose, its owners and investors, the assets it will hold, the rules it must meet and how its money will move.

Frequently Asked Questions

1. What is an SPV in Ireland?

An Irish Special Purpose Vehicle (SPV) is a company established for a particular investment, acquisition, financing or asset-holding transaction.

It is not a separate legal form. Irish SPVs commonly use an LTD or Designated Activity Company (DAC), and certain qualifying financial-asset vehicles may use the Section 110 tax regime.

2. What is a Section 110 company?

A Section 110 company is an Irish tax-resident company that meets specific conditions for holding or managing qualifying financial assets, often in securitisation or structured-finance transactions.

The qualifying assets must generally have a market value of at least €10 million when first acquired or held. The company must also notify Revenue using Form S.110 within the prescribed period.

3. How do I set up an SPV in Ireland?

Choose the SPV's purpose and ownership structure, select an LTD or DAC, arrange an Irish registered office, appoint directors and a company secretary, and file Form A1 with the constitution through the Companies Registration Office (CRO).

The company must meet Ireland's EEA-resident director rule or a recognised alternative and register its beneficial owners with the RBO within five months of incorporation.

4. How much does it cost to set up an SPV in Ireland?

The CRO charges €50 to incorporate a company online. Optional name reservation costs €25, credited against the incorporation fee if used within 28 days.

Those are statutory charges, not the total establishment cost. Institutional and Section 110 SPVs can incur substantially higher legal, tax, director, administration and banking expenses depending on the transaction.

5. Can a non-resident or foreign-owned company set up an Irish SPV?

Yes. Overseas individuals, funds and companies may own an Irish SPV, and directors can live outside Ireland.

However, at least one director must normally reside in the European Economic Area (EEA). Alternatives include a Section 137 bond providing €25,000 of cover or, for qualifying companies, a certificate confirming a real and continuous link with economic activity in Ireland. The bond cover is not the premium payable.

6. How long does it take to set up an SPV in Ireland?

The CRO aims to issue incorporation certificates within ten working days for correctly completed ordinary online applications. Its faster Fé Phráinn scheme targets five working days for eligible participants using pre-approved documents.

Complex ownership arrangements, director-residency compliance and transaction documents can add time. Incorporation does not automatically mean a business account is approved or ready to use.

7. Can an Irish SPV open a business bank account?

Yes. Newly incorporated Irish SPVs can apply for business accounts even without an established trading history.

Approval depends on the provider's assessment of ownership, source of funds, transaction purpose and expected payments. Some banks restrict non-trading SPVs or foreign-owned structures, while specialist providers may support them, subject to eligibility and compliance checks.

8. What documents are needed to open an Irish SPV business account?

Common requests include the CRO Certificate of Incorporation, constitution, shareholder and director details, ownership chart, beneficial ownership information, identity documents and proof of address.

Providers may also request evidence of investor funds, investment or acquisition agreements, loan documentation and projected account activity. Institutional or Section 110 structures may need additional supporting records.

9. Is Banq Global a bank?

No. Banq Global is a specialist business-account provider, not a bank. Its accounts and payment services are supplied through regulated financial partners.

While client funds are not covered by Ireland's Deposit Guarantee Scheme (DGS), they are safeguarded by our regulated financial partners in segregated accounts held with Tier-1 banks, in accordance with applicable regulatory requirements.

10. Is a notary required to incorporate an Irish SPV?

Generally, no. The standard Irish LTD or DAC incorporation process involves filing Form A1 and a signed company constitution with the CRO through CORE, without a mandatory notarial deed.

Supporting documents still need to meet the CRO's signing and filing requirements. Complex cross-border transactions may separately involve notarised or certified documents for other purposes.

11. Does a Section 110 company need to register with the Central Bank?

Section 110 companies generally have Central Bank statistical reporting obligations, rather than automatic regulatory authorisation simply because they use the regime.

A Section 110 SPV not already reporting as a financial vehicle corporation (FVC) must notify the Central Bank within five working days of its first financial transactions and submit quarterly returns within 29 working days of quarter-end. FVCs follow a separate reporting process.

12. What ongoing compliance does an Irish SPV have?

An Irish SPV generally files a CRO annual return within 56 days of its annual return date and submits Corporation Tax returns to Revenue within nine months of the accounting period ending. It must also maintain beneficial ownership information and report relevant changes.

Depending on its structure and activities, it may need audited accounts, VAT filings and Section 110 or other Central Bank reports.