The two-hub advantage
Ireland has led the global aircraft leasing industry for over four decades, hosting 14 of the world’s top 15 lessors and more than 5,000 active leasing vehicles. Its appeal lies in its treaty network, aviation-specific legislation, and deep professional expertise.
India, through its Gujarat International Finance Tec-City (“GIFT City”), is building a complementary hub. With tax incentives, simplified compliance, and a framework aligned with international standards, GIFT City allows lessors to operate within India’s financial ecosystem while maintaining international credibility.
Together, the two hubs offer strong advantages: Irish structures provide global reach and treaty access, while GIFT City delivers local alignment, lower costs, and access to Indian operators.
The role of SPVs
Most cross-border leases use Special Purpose Vehicles (“SPVs”) to ringfence assets and manage liabilities. A common structure sees an Irish SPV acquire the aircraft, lease it to a GIFT City entity, which then subleases to the Indian operator.
This arrangement supports:
- Risk isolation between assets and portfolios
- Access to financing secured against specific leases
- Tax advantages from Irish treaties and Indian incentives
- Clearer administration across jurisdictions
Managing SPVs consistently is critical. Each entity brings incorporation requirements, governance obligations, reporting deadlines, and lender oversight.
Compliance as a decisive factor
Structuring across jurisdictions creates efficiency but also increases compliance obligations. Irish SPVs must report to the Companies Registration Office, Revenue Commissioners, and the Central Bank. GIFT City entities are overseen by the International Financial Services Centres Authority. Both must also comply with international standards such as the Foreign Account Tax Compliance Act, the Common Reporting Standard, and EU Directive 2018/822 on cross-border tax arrangements.
Non-compliance can result in penalties, loss of treaty benefits, and reputational risk with regulators and lenders. The cost of getting it wrong is significant.
The case for integrated support
Managing obligations in both jurisdictions can overwhelm internal teams. A coordinated provider model with oversight of Irish and GIFT City structures reduces the chance of missed filings, avoids duplicated costs, and maintains lender confidence.
With hundreds of aircraft expected to be leased into India in the coming years, lessors that combine effective structuring with integrated compliance will be best placed to capture the opportunity.
Download the aircraft leasing eBook
The future of aircraft leasing into India is not just about acquiring aircraft, it is about creating structures that balance efficiency with compliance.
Lessors that establish capabilities in both Ireland and GIFT City today will not only serve immediate demand but also build a platform for growth across South Asia.
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