Michael Noonan (Limerick City, Fine Gael) | Oireachtas source

The section provides that an individual shall not be entitled to relief in respect of any shares unless the shares are subscribed and issued for bona fide commercial purposes and not as part of a scheme of arrangement, one of the main purposes of which is the avoidance of tax. If the Revenue in its prior approval process believes that one of the principle purposes of the investment is the avoidance of tax it will not approve the investment. If Revenue thought the scheme was being abused it would inform the Department in the normal way so that the gap could be closed in a finance Bill. That is how Revenue operates. I will raise the issue with Revenue.