The special purpose vehicles used by the likes of Goldman Sachs and Cerberus that exploited a tax-free loophole when buying up portfolios of distressed Irish property assets must be kicking themselves on the double this week.

The loophole, originally intended for global debt securitisation, has been closed by the State after sustained reporting of the "section 110" issue in this newspaper and elsewhere, and complaints in the Dáil from TDs Stephen Donnelly and Pearse Doherty.

Not only is the tax-free loophole gone, however. Irish property-owning SPVs now hold billions of euro worth of assets that are now effectively stuck in complex structures with a headline tax rate of 25 per cent, double the normal rate.

As they say in the inner city area that surrounds Dublin’s docklands financial district: “Hate tha’...”.

Following lobbying in the late 1990s from the local law firms and accountants that service international funds, the State created a SPV (section 110) regime to attract global financial securitisation to these shores.

Because no actual trading was taking place in Ireland, the regime was set up to make Irish-based SPVs tax neutral.

When the Irish economy crashed and the State bought and then started selling portfolios of distressed property loans, international funds cottoned on that the loans could be housed in these SPVs, avoiding Irish tax.

It was probably one of the greatest giveaways in the history of the State.

The SPVs had a headline rate of 25 per cent due to their investment, as opposed to trading, income. It was good optics, if little else.

But because of the way they were set up, they never declared any profits at all. 25 per cent of nothing is still nothing.

With the closure of the loophole for Irish property, some SPVs have gone, overnight, from paying no tax to paying twice the rate of everybody else.

It also isn’t all that easy for them to strip the assets out of the complex structures and flip them into normal companies, paying a normal rate.

They’re effectively stuck. Is that the distinct whiff of tax justice in the air?