experience of U.S. distressed debt funds abusing Irish Section 110 SPVs in 2012–2016 is notable. However, OFCs play a key role in providing the legal structure for global securitisation transactions that could not be performed from the main financial centres. Promotion of growth The well-regulated OFCs which have English-based legal systems are used to promote global economic growth by providing a preferred platform from which global capital is more readily deployed. It is said that there are strong academic advocates, and studies, on both sides of this argument yet in reality, the very volume of investment and trade is testament to this point. Some of the most cited researchers into tax havens/offshore financial centres, including Hines, Dharmapala and Desai show evidence that, in certain cases, OFCs promote economic growth in neighbouring higher-tax countries, and can solve issues that the higher-tax countries can have in their own tax or regulatory systems, which deter capital investment. The latter point is important as global investors take into account risk as well as return. As is evident in examples like China Evergrande, non-Chinese lenders and investors routinely use the BVI and Cayman as investment vehicles on the basis that any dispute or default would be a matter for the Courts of those jurisdictions and their English-derived laws. The reduced risk is reflected in a reduced cost of capital, incentivising international investment. In this example, the difficulty of enforcement when dealing with Chinese onshore business already meant the investments were of considerable risk, yet some bondholders were able to enforce their security after default. The most cited paper specifically on OFCs, also came a similar conclusion (although recognising that there are strong negatives as well): However, other major tax academics take the opposite view and accuse Hines (and others) of mixing cause and effect (e.g. the capital investment would have come through the normal taxed channels had the OFC option not been available), and include papers by Slemrod, and Zucman. Critics of this theory also point to studies showing that in many cases, the capital that is invested into the high tax economy via the OFC, actually originated from the high-tax economy, and for example, that the largest source of FDI into the U.K., is from the U.K., but via OFCs. While the British Overseas Territories are usually the entities pilloried in the press, ironically most Base Erosion and Profit Shifting (BEPS) and aggressive tax