banks (some under EU and US sanctions) had also been using the Irish Section 110 SPV to funnel over €100bn through the IFSC. Further academic studies showed that the IFSC SPV sector was operating in an almost unregulated fashion where structures were more akin to brass plate companies. Other former Central Bank of Ireland regulators also publicly highlighted their concerns. Discussed further in unregulated shadow banking. Financial sectors A 2015 Irish Government IFS 2020 Strategy Paper, lists the Irish financial services sector as comprising over 400 companies, employing over 35,000 people (one third outside Dublin), with over €3.2 trillion in funds under administration, providing €2bn in taxes and €2.3bn in wages and salaries. KMPG estimate the IFSC constitutes 7% of Irish GDP. The IFSC has now become one of Europe's most important centres for , and , and ultimately became the birthplace of and global leader in . Some of the largest offices in the IFSC are those of the major Irish accounting and law firms. They have become associated with the creation and development of international tax management tools, (such as the Double Irish, single malt, and capital allowances for intangible assets (CAIA) BEPS tools; and Section 110 SPV, QIAIF and ICAV zero-tax legal structures), leading to concerns of Ireland as a tax haven. In 2017, a University of Amsterdam study estimated that the IFSC was one of the world's largest conduit OFCs for facilitating global corporate tax avoidance. In 2018, a Gabriel Zucman study estimated that Ireland had become the world's largest corporate tax haven by virtue of its use as a Conduit OFC. Some of the main sectors of financial services activity carried out in the IFSC are outlined below: Fund administration and domiciling The original proposal for the IFSC was that it would become a location for high-margin activities such as investment management, banking and securities trading given its low tax rate and proximity to the major centres of London and Paris. However, ultimately few of these companies established offices which offered these services or relocated to Dublin in the following years and while the level of material employment has grown significantly relative to its former size, it is still well below many of the larger European financial centres in overall terms such as Frankfurt, London or Paris. Many of the notable fund and investment managers are dealing mostly with domestic businesses e.g. - Irish Life