In this regard, more advanced and/or aggressive Irish tax-neutral vehicles, which are fully tax-free and can be operated in greater secrecy from public views, such as the Qualifying investor alternative investment fund (QIAIF), or LQIAIFs and QIFs, were not deemed suitable for the global securitisation transaction marketplace. As an ordinary Irish company, a Section 110 SPV usually takes one of 3 main forms:  A "qualifying company" under Section 110 of the 1997 TCA means a company which:   The list of "qualifying assets" which can be held inside an Irish Section 110 SPV is large (it has been extended with subsequent Irish Finance Acts). It goes well beyond the original classic securitisation categories and currently includes:  There are three key elements relevant to structuring Irish Section 110 SPVs (as discussed in attached references):  These structuring elements are also discussed in more detail in the briefing notes issues by the Revenue Commissioners on Section 110 SPVs. In common with most securitisation vehicles, Irish Section 110 SPVs use an orphan structure in which the equity is held by an unconnected third party who has no effective rights or controls on the SPV. Irish registered charitable trusts were a common choice (some Irish law firms went so far as to create their own in-house registered charities). However, a public scandal in 2016 regarding use of Irish Section 110 SPVs in domestic Irish tax avoidance (see ) led to a ruling by the Irish Charity Regulator prohibiting Irish registered charities from owning equity in Section 110 SPVs. Orphaning is a potentially strong tax avoidance tool as it allows equity to be restructured into tax-free debt (see ), and the Revenue Commissioners reserve the right to challenge cases created for tax avoidance, although they have never done so in practice. The TCA 1997 legislation includes a headline tax rate of 25% on non-trading income so that the SPV is regarded as an Irish taxable entity. Thus, the Section 110 SPV is not presented overtly as a tax-free vehicle (i.e. unlike an Irish QIAIF), which would attract adverse attention from other tax authorities (under tax treaty rules), or regulators (e.g. EU or OECD). To get to a zero-tax position, the TCA 1997 allows "Profit Participation Notes" (PPNs). These are artificial internal loans to the SPV, whose rate of interest can be sufficiently variable to absorb all income/gains generated in the SPV.