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Special Purpose Entities and Pass-Through

Special Purpose Entities and Pass-Through

In 2024, 8% of Inward FDI in Ireland was attributed to Special Purpose Entity firms. Pass-through investment made up 31% of Inward FDI

CSO statistical release, , 11am

Financial Globalisation and FDI Statistics

In the modern global economy, substantial flows of cash are transferred daily between many different countries, a lot of which have different taxation systems and accounting practices. This reality necessitates a separation of funds going into economies, from funds that are intended as actual investment, and those which are simply passing through. For a globalised economy, like Ireland, these complex capital flows can sometimes lead to difficultly in the interpretation of macroeconomic statistics.

Therefore, it is becoming increasingly important to adopt new methods in FDI statistics to reduce globalisation effects. In line with operational guidance from the IMF and Eurostat, as well as through the implementation of international best practices (the Finnish pass-through methodology), the following three statistical procedures aim to establish FDI figures that are more in tune with real economic phenomena.

SPE Method

A Special Purpose Entity (SPE) is a company set up for reasons that are beyond the production of goods and services. Often SPEs are established for financing purposes or to hold certain assets or liabilities. The present IMF guidance defines them as businesses which: have no more than five employees, have very little production within their resident economy, have a foreign ultimate controlling parent, and have a high ratio of foreign assets relative to domestic assets. A question for many countries such as Ireland, the Netherlands and Luxembourg (countries which exhibit a large disparity in FDI figures with their European counterparts), is to what extent these types of firms may influence investment figures, making them more difficult to interpret.

“The use of SPE structures has rocketed in a context of multifaceted and flexible multinational enterprise (MNE) structures, which have become increasingly global and seek to obtain benefits from different legal and tax regimes” (IMF SPE Task Force, 2018). Considering these factors, the EU and the OECD is encouraging member states to report more information on SPEs.

Figure 3.1 shows that SPEs account for the majority of FDI for some countries such as Luxembourg and Hungary. For most EU countries however, the percentage of SPE-based FDI is far lower. Some countries such as France and Germany report that none of their FDI can be attributed to SPEs. 8% of Ireland’s FDI in 2024 can be attributed to SPEs based on the IMF definition.

% of FDI Attributed to SPEs
Luxembourg63.1421666546113
Hungary54.5231326653295
Denmark11.8043100770073
Belgium8.10069522895872
Ireland7.95786183111468
Spain5.19772223979758
Estonia3.75091408435494
Iceland2.10822154948397
Sweden1.65868701424851
France0
Germany0
Slovak Republic0
Slovenia0
Austria-2.09684024534457

Source publication: Foreign Direct Investment Annual 2024

Get the data: OECD Statistics

As seen in Figure 3.2, SPEs operating in Ireland contribute a relatively small amount of FDI when compared to the rest of the international businesses established here. The figures maintain a relative consistency over the period shown, which is consistent with the idea that many of these types of firms are established with a view to holding specific financial assets over a length of time. In 2024, SPE FDI amounted to €86.7 billion.

SPE FDITotal Inward FDI
201415.18534385.466223292
201515.77093846.719784636
201622.60582817.775081693
201740.4048934.588289382
201828.01884951.980806973
201931.795611134.5419
202047.683231165.0693
202145.213241263.5141
202227.3804253511350.2289
202325.02870531186.56602637177
202486.673028261089.1497

Source publication: Foreign Direct Investment Annual 2024

Figure 3.3 shows FDI attributed to SPEs as a percentage of total Irish inward FDI. The figures are relatively stable between 2% and 4% over the period shown. In 2024, 8% of FDI was attributed to SPE firms. The increase on previous years was due to population changes.

Percentage of FDI Attributed to SPE Firms
20143.95462684888012
20151.86552432810189
20162.77289654202108
20174.35445820917237
20182.96720101088104
20192.80834299018534
20204.1109812147437
20213.59423437403115
20222.02783582479978
20232.10933945045871
20247.95786183111468

Source publication: Foreign Direct Investment Annual 2024

As illustrated in Figure 3.4, the 25 firms that receive the most amount of FDI in Ireland are responsible for the majority (approximately 61% in 2024) of Ireland’s FDI inward positions. In relation to the other stratified compilations of firms, the SPEs have a relatively low amount of FDI that is attributed to them.

Top 2526-5051-7576-100101+SPEs
201465.440541690829518.86815986577079.87748709746296.52232789774136-0.7085165518044293.95462684888012
201574.074908426967311.76714171410455.681216464229853.600834737722424.875898656975961.86552432810189
201675.201892501511113.5478091517556.213153614501464.009795989575891.027348742656612.77289654202108
201774.356296397697612.54399380268486.234424409727473.693986452388913.171298937501154.35445820917237
201867.230375370958914.14683106427237.389089665730154.529037506260836.704666392777892.96720101088104
201966.495896911508715.40012327561017.915299595973253.976774802175186.211905414732822.80834299018534
202066.554936723782316.42934145798537.95248571622483.746243218109735.316992883897894.1109812147437
202163.524103380021217.70779927090778.844965277618994.19889002277765.724242048674533.59423437403115
202266.896118947204816.96031421112187.880144826156293.885018006495194.378404009021942.02783582479978
202364.986818798539218.10138470137479.399227369307184.744859321834172.767709808944692.10933945045871
202461.36114895051418.809755937088510.32980065884815.12945013396654.369844319582977.95786183111468

Pass-Through Method

The second method used to mitigate globalisation effects from FDI statistics involves estimating pass-through, which can be defined as foreign multinationals investing in their Irish affiliates which then subsequently invest in another economy. It has been shown globally that there exists a strong correlation between inward and outward FDI flows (Blanchard & Acalin, 2016). This suggests that FDI statistics are being inflated as investments flow through their economies instead of entering them. The result of this is that a highly globalised economy’s inward and outward FDI figures may be inflated.

Currently, there is no benchmark definition of pass-through FDI since it can come in different forms and largely depends on the level of operational activity within MNEs in an economy. For instance, although the SPE method can explain the large majority of FDI for Luxembourg and the Netherlands, it fails to explain a similar portion of Ireland’s FDI figures. This is because MNE activity in Ireland is different to that of Luxembourg or the Netherlands. Many multinationals here are non-financial enterprises, often with large employment i.e., firms that fall outside the definition of an SPE. Therefore, pass-through activity in these regular operational enterprises may not be captured using the SPE method.

The method used in this report to estimate pass-through FDI occurring in Ireland involves comparing a firm’s FDI assets and liabilities. The lower of these is then chosen and used as the estimate of pass-through FDI for that enterprise. The results are then aggregated to give an overall estimate of pass-through FDI in Ireland. The premise for this method is that it captures non-conventional FDI activity among all firms, not just SPEs. The method is formally shown at the end of this chapter and is based on pass-through analysis first introduced by Leino and Ali-Yrkko (2014).

Figure 3.5 shows this method applied to Irish FDI data. In 2024, pass-through FDI was estimated to be €610 billion. For a better conceptual understanding of this figure, it can be viewed in terms of a % of FDI liabilities where 38% of FDI liabilities in 2024 are estimated to be pass-through.

FDI AssetsFDI LiabilitiesPass-ThroughPass-Through as a % of FDI Liabilities
2014930.853613876807.39593565460.84987614157.0785479332379
20151339.2241347.7447684.39335536250.7806378583422
20161438.43571423.5502782.09449421354.9397200192167
20171378.26211473.3396796.7810142854.0799293170427
20181491.39221595.0113905.27536244356.7566739146613
20191551.57721683.504842.27633310550.031145343581
20201473.71051599.3374735.08448366845.9618141655413
20211827.20531770.4523833.66595452747.0877387957303
20221777.4161916.646978.17200981551.0356116786824
20231557.63551588.3708601.07884368937.8424763089954
20241690.82071588.4138610.25547715638.4191749754378

Source publication: Foreign Direct Investment Annual 2024

FDI is presented on an asset and liability basis in Figure 3.5, whereas in the SPE part of this publication it is presented on a directional basis. For a breakdown of the difference between these two presentations see this information note. The difference between FDI inward (directional) and FDI Liabilities (asset and liabilities) essentially comes down to the removal of reverse investment i.e., investment from the subsidiary or child firm back to the parent of the organisation.

Figure 3.6 shows pass-through relative to FDI Inward. When we analyse pass-through with respect to the directional presentation of FDI or FDI Inward, it’s percentage of the total drops to 31% in 2024. The reason for this is that there exists an overlap between the funds excluded though the filter of removing reverse investment and those removed from filtering out pass-through.

FDI Inward RemainderPass Through
201484.000233899301.465989393
2015467.917168561378.802616075
2016410.539813058407.235268635
2017594.877014761339.711274621
2018501.805552152450.175254821
2019789.620388532344.921511468
2020884.161131393280.908168607
2021933.233116991330.280983009
2022954.2198772396.0090228
2023927.42606185577259.139964516
2024756.885191414332.264508586

Source publication: Foreign Direct Investment Annual 2024

Figure 3.7 shows pass-through FDI by NACE classification. In 2024, manufacturing enterprises engaged in the most pass-through activity with €270 billion. Financial and insurance enterprises followed second with €164 billion. Manufacturing enterprises in 2023 were approximately €206bn lower year on year, largely due to corporate restructuring.

Financial & Insurance ActivitiesManufacturingProfessional, Scientific, and TechnicalInformation & Communication
2014193.9464229895.73478901868.94518312420.02110338
2015220.147607266157.307032298170.53565386626.768217302
2016243.764083227163.33063668215.421582833.203332337
2017171.65518023161.86017335170.054715188179.03956856
2018279.606421466230.276986875170.619673575135.995202161
2019185.192095291215.040060278230.6999172117.84844559
2020149.757971244239.177928376136.927755186143.02296154
2021196.093666246329.773692547116.63445395109.140127
2022255.597191269411.193473915128.42988706268.403484222
2023143.634809862205.53169986859.38500357558.262615239
2024163.950463815269.91142873834.81537600760.24131813

Source publication: Foreign Direct Investment Annual 2024

Figure 3.8 shows that firms with an ultimate controlling parent in the US have engaged in the most pass-through activity, totalling €449 billion in 2024. The estimated pass-through occurring in firms with an Irish ultimate controlling parent is mostly coming from redomiciled PLCs. These PLCs can have FDI liabilities coming from debt instruments such as loans and trade credits. Given that these firms have large outward FDI positions, the applied method will label their FDI liabilities as pass-through.

United States Ireland United KingdomFranceBermuda
2014320.14129712973.0169594410.39376234311.50298648111.053776436
2015437.568833259168.54348645919.03881183711.23351484111.229094429
2016488.83734662212.64331732118.72368818512.8424830297.719740765
2017534.133332293174.74785785918.30257888812.4139682849.490425691
2018628.264128351179.47245444118.52541151413.79454579310.533744592
2019515.37054473209.3161797228.47920743210.47198964613.207941862
2020499.76191085132.9067729016.97154622410.652255935.2202066401
2021585.016554072149.7256576687.01302494411.9200885134.292309313
2022642.357366345226.50386042210.19044218615.3373310155.408842133
2023399.650092998.77235729510.0654439638.9752471545.378647288
2024448.5882854874.79551467411.03420139213.6672995935.784899573

New Pass-Through Method

This new method for estimating pass-through is proposed in the IMF Direct Investment Task Team guidance note ‘D.6 Ultimate Investing Economy/Ultimate Host Economy and Pass-through Funds’. This method involves calculating pass-through on a directional basis and at the level of the residency of the ultimate investor.

The above estimates for pass-through activity are derived using FDI asset/liability data. However, when seeking to analyse the effect that FDI has on the economy, it is more precise to look at FDI figures presented using the directional principle which involves a netting process to remove reverse investment.

Pass-through funds in an economy are carried out by foreign-owned parent firms; that is, by entities that are in the middle of the chain that are both direct investment enterprises and direct investors. A breakdown of the outward FDI positions based on the residency of the ultimate investor gives an indication of the amount of funds passing through the economy back to the investing countries.

Figure 3.9 shows that in 2024, pass-through FDI was estimated to be €206 billion. As a percent of inward FDI, 19% is estimated to be pass-through. This compares to the 38% of FDI liabilities that are estimated to be pass-through in Figure 3.5, where the asset/liability principle does not capture the effects of reverse investment.

FDI InwardFDI OutwardPass-ThroughPass-Through as a % of Inward FDI
2014385.466223292511.262235803126.09650364417832.7127244943214
2015846.719784636838.926049401223.14520355381526.3540793073287
2016817.775081693833.475294983228.87324410822327.9873096199504
2017934.588289382835.893692123310.41003466313733.2135591885489
2018951.980806973844.615112207271.02267868371528.4693427323899
20191134.54191002.6459241.060460514621.2473827995775
20201165.06931039.473333.616168512528.6348776431153
20211263.51411320.267352.8037254719527.9224209268381
20221350.22891210.999386.75775276328.6438657003268
20231186.566026371771155.83072977362289.81460244324.4246502935182
20241089.14971191.55691716585206.31706825618.9429486374554

Source publication: Foreign Direct Investment Annual 2024

Figure 3.10 shows a country breakdown of the above pass-through figures. This estimation method shows that firms with an ultimate controlling parent in the US have engaged in the most pass-through activity, totaling €150 billion in 2024. The difference in the estimates for pass-through to firms with an ultimate controlling parent in the US in Figures 3.10 and 3.8 can be explained by the netting of reverse investment. The remaining countries are grouped together for confidentiality purposes.

United StatesOther
201450.2271052275.8693984241777
2015143.27807237579.8671311788146
2016169.88490847858.9883356302225
2017260.98334205249.4266926111375
2018216.06323427754.9594444067145
2019185.34157968755.7188808276001
2020282.96970302950.6464654835
2021290.61109842762.1926270449502
2022311.19564200875.562110755
2023212.90177661276.912825831
2024150.22002021756.097048039

Round-Tripping Method

The above two statistical procedures aim to mitigate the effects that the complex financing and ownership structures of multinational enterprises have on the interpretation of FDI statistics. This third procedure seeks to do the same by of estimating the levels of round-tripping that exist within FDI in the Irish economy.

Round-tripping refers to domestic funds which leave an economy and return back as FDI. It is unlikely that round-tripping brings the additional benefits associated with truly foreign investment.

Statistics on round-tripping are useful for identifying if there is a problem with an economy’s investment policy regime. Round-tripping could also have other negative consequences on the investing economy, such as reducing tax revenues for or regulatory oversight by the investing economy (Borga, 2016). The below provides two estimates for round-tripping.

Figure 3.11 shows that firms with an ultimate controlling parent in Ireland totalled €4 billion in inward FDI in 2024. This gives an estimate of the levels of round-tripping engaged in by Irish ultimately controlled firms. The decreases in round-tripping in recent years were due to corporate restructuring.

Irish UCP FDI Inward Remainder
201425.120274672360.34594862
2015108.621236954738.098547682
2016115.682443647702.092638046
201780.88352026853.704769122
201879.904905244872.075901729
2019114.3203852241020.221514776
202042.637671921122.43162808
202150.1515008561213.362599144
2022108.075117551242.15378245
20232.5512594061184.01476696577
20244.38183447491084.7678655251

Source publication: Foreign Direct Investment Annual 2024

Figure 3.12 compares the levels of inward and outward FDI for firms with an ultimate controlling parent in Ireland. This gives an alternative estimate of the levels of round-tripping engaged in by Irish ultimately controlled firms.

Irish Outward FDIIrish Inward FDI
2014385.16590625525.120274672
2015615.781138882108.621236954
2016604.602308168115.682443647
2017525.48391045880.88352026
2018573.59267811479.904905244
2019761.585667889114.320385224
2020705.85722504142.63767192
2021967.46377254750.151500856
2022824.241349516108.07511755
2023866.0157960612.551259406
2024985.2395156044.3818344749

Source publication: Foreign Direct Investment Annual 2024

Pass-Through Estimation Method 

Pass-through formula

 where Ii,t denotes inward FDI position of an enterprise and 0i,t is the outward FDI position.

References

Blanchard, Olivier & Acalin, Julien (2016), “What does Measured FDI Actually Measure?”, Peterson Institute for International Economics.

Borga (2016), “Not all foreign direct investment is foreign: the extent of round-tripping”, FDI Perspectives.

D.6 Ultimate Investing Economy (UIE)/Ultimate Host Economy (UHE) and Pass-through Funds, Washington, D.C., 2020.

Final Report of the Task Force on Special Purpose Entities, Washington, D.C., 2018 (PDF).

Leino, Topias & Ali-Yrkko, Jyrki (2014), “How Well Does Foreign Direct Investment Measure Real Investment by Foreign-Owned Companies? – Firm-Level Analysis”, Bank of Finland Research Discussion Papers, vol. 12.