I am advised by the Central Bank of Ireland that it does collect statistical data on special purpose entities whose activities involve purchasing and owning commercial and residential property.
Financial Vehicle Corporations (FVCs) engaged in the securitisation of property-related assets include:
RMBS (Residential Mortgage Backed Securities) – • securities backed by cash flow resulting from mortgage loans that have been secured on residential properties
CMBS (Commercial Mortgage Backed Securities) – • securities backed by cash flow resulting from mortgage loans that have been secured by commercial properties, such as multi-family dwelling, malls, offices, shops, restaurants, etc. CMBS is a considerably smaller category than RMBS.
Other SPEs involved in property ownership include:
Financial Leasing – • vehicles that
lease, or sub-lease, an asset on terms by which the risks and rewards of ownership of the leased asset are borne by the lessee. Examples include mortgage financing arrangements, finance/capital leases, and synthetic leases.
These represent a small portion of overall Other SPEs activity.
Investment Fund-Linked• – some vehicles in this category hold property on behalf of property funds. While Investment Fund-Linked represents the largest Other SPEs category in Q3 2025, property-fund related vehicles are likely to represent a small subset.
The Deputy will be aware that section 110 of the Taxes Consolidation Act 1997 (TCA 1997) deals with the taxation regime for special purpose vehicles (SPVs) established in Ireland to securitise assets. For completeness, I am advised by Revenue that section 110 companies are not permitted to own Irish property assets (land and buildings) directly.
