which were eroded in 2003, 2008, 2011 Finance Acts (see Section 110 article). L–QIAIFs – QIAIFs were introduced in 2013 with the new EU AIFMD regulations, but expanded in 2018 into a full Debt–based BEPS tool. Irish tax-law firms expect the Irish KDB terms will be brought into alignment with the CAIA BEPS tool terms in the future. Debt–based BEPS tools Section 110 SPV A Section 110 Special Purpose Vehicle ("SPV") is an Irish tax resident company, which qualifies under Section 110 of the 1997 Irish Taxes Consolidation Act ("TCA"), by virtue of restricting itself to only holding "qualifying assets", for a special tax regime that enables the SPV to attain full tax neutrality (i.e. the SPV pays no Irish corporate taxes). It is a major Irish Debt–based BEPS tool. Section 110 was created to help International Financial Services Centre ("IFSC") legal and accounting firms compete for the administration of global securitisation deals. While they pay no Irish taxes, they contribute circa €100 million annually to the Irish economy from fees paid to the IFSC legal and accounting firms. IFSC firms lobbied the Irish State for successive amendments to the Section 110 legislation, so that by 2011, Section 110 had become an Irish Debt–based BEPS tool, for avoiding tax on Irish and international assets. In 2016, it was discovered that U.S. distressed debt funds used Section 110 SPVs, structured by IFSC professional service firms, to avoid material Irish taxes on domestic Irish activities, while State-backed mezzanine funds were using Section 110 SPVs to lower their clients Irish corporate tax liability. Academic studies in 2017 note that Irish Section 110 SPVs operate in a brass plate fashion with little regulatory oversight from the Irish Revenue or Central Bank of Ireland, and have been attracting funds from undesirable activities (e.g. sanctioned Russian banks). These abuses were discovered because Section 110 SPVs must file public accounts with the Irish CRO. In 2018 Central Bank of Ireland overhauled the little-used L–QIAIF vehicle, so that is now offers the same tax benefits on Irish assets held via debt as the Section 110 SPV, but without having to file Irish public accounts. Stephen Donnelly TD estimated that U.S. funds would avoid €20 billion in Irish taxes from 2016 to 2026 on circa €40 billion of Irish investments (2012–2016), by using Section 110 SPVs. L–QIAIF The Irish QIAIF regime is exempt from all Irish taxes and duties