Special Purpose Vehicles (“SPVs”) are not simply administrative entities in aircraft leasing; they are the structural foundation that makes India’s projected $35 billion aviation market by 2030 accessible. In the Ireland-GIFT City model, SPVs provide the framework that turns regulatory obligations into strategic advantage.
Why SPVs matter
Each aircraft represents significant asset value and complex financing arrangements. Consolidating these into a single entity creates unnecessary risk. SPVs separate exposures and deliver clear benefits:
- Risk isolation: Issues with one aircraft remain contained within its own SPV
- Financing flexibility: Each SPV can carry its own debt terms, security, and lender relationships
- Tax efficiency: Structures can be tailored for each aircraft and jurisdiction
- Operational clarity: Transparent cash flows and reporting build trust with lenders and investors
SPVs allow lessors to expand portfolios efficiently while maintaining oversight of risk and financing.
Ireland’s SPV strength
Ireland has been the centre of the global aircraft leasing industry for over four decades. Its appeal lies in its extensive treaty network, established legal framework, and specialist professional expertise.
Advantages include:
- A double taxation treaty with India that provides favourable treatment on lease payments
- Access to global debt markets and export credit facilities
- Predictable legal outcomes under a common law system and Cape Town Convention
- A concentration of aviation service providers supporting efficient transactions
These benefits become even stronger when managing large portfolios, as each additional Irish SPV draws on the same infrastructure.
GIFT City’s SPV role
GIFT City provides the local presence that lessors require when working with Indian carriers. A GIFT City SPV creates operational alignment and regulatory acceptance, while the Irish SPV retains international financing and treaty benefits.
A dual-SPV structure typically works as follows:
- An Irish SPV acquires and finances the aircraft
- A GIFT City SPV provides local presence and regulatory compliance
- The Irish SPV leases to the GIFT City SPV
- The GIFT City SPV subleases to the Indian operator
This approach delivers both treaty and domestic tax advantages, while ensuring oversight that is recognised by Indian regulators.
Portfolio-level advantages
SPVs at scale are not overhead, they are structured portfolio management. Large dual-jurisdiction SPV portfolios provide:
- Diversified risk across assets
- Flexible financing tailored to each aircraft
- Scalable operations supported by standardised processes
- Stronger lender confidence from clean structures and transparent reporting
For lessors building Indian portfolios, this approach supports both resilience and long-term growth.
Compliance as a strength
Dual-jurisdiction SPV portfolios carry significant compliance responsibilities. Irish SPVs 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 meet international standards such as the Foreign Account Tax Compliance Act, the Common Reporting Standard, and EU Directive 2018/822 on cross-border tax arrangements.
With the right systems, these requirements become a strength rather than a burden, creating consistency across large portfolios and building lender and regulator confidence.
Building an SPV strategy for India
The question is not whether to use SPVs - they are fundamental to professional aircraft leasing. The decision is whether to rely on single-jurisdiction models or to adopt dual Ireland-GIFT City structures that combine efficiency, financing access, and regulatory alignment.
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