Belfast Telegraph

Company behind Dublin department store purchase and closure paid just £185 in tax

By Sean Duffy

The Irish subsidiary of a US real estate giant that part-funded the €29m (£25m) purchase of Clerys department store - leading to its controversial closure pending redevelopment - paid just €214 (£185) tax on its Irish activities last year.

Qrea Ireland, which manages over €35m (£30m) of assets in Ireland, is one of more than 2,100 companies availing of S110 tax neutral status.

Qrea's US parent Quadrant, which has an estimated €5.7bn (£4.9bn) in global assets, separately received €50m (£43m) in funding from the Irish government's Strategic Investment Fund (ISIF) last November, but has undertaken no investments to date with its state funds.

Section 110 of the Taxes Consolidation Act 1997 is regarded as the cornerstone of Ireland's onshore debt-securitisation regime.

The vehicle allows investors to acquire, manage and trade in a vast range of assets, including securities, aircraft, financial assets and non-performing loans, such as mortgages, in a tax-neutral manner.

There are now more than 2,100 S110 special purpose vehicles operating in Ireland, whose popularity has more than trebled since 2010 when €74bn (par value) worth of toxic property debts were transferred to the National Asset Management Agency (Nama).

But following the extensive use of S110 vehicles in the acquisition of distressed property assets, the Republic's Revenue has launched a sample audit into at least 40 companies suspected of abusing the law.

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