Living in the computer records of corporate secretarial firm Intertrust on the bank of the Grand Canal in south Dublin, a string of companies with no employees are named after villages and islands in south-west England: Launceston, Pentire, Otterham, Gulland… Their common purpose over the past decade has been to act as special-purpose vehicles for the US hedge fund management firm CarVal in successive acquisitions of distressed debt portfolios in Ireland. They operate under Section 110 of the tax code, allowing them to shift profits from debt collections under the form of interest payments on intercompany debt extended by CarVal’s…
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