Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

As a point of interest, section 110 companies, which are what Deputy Donnelly has raised with particular reference to loopholes and the proposed amendment, have nothing at all to do with qualified investor funds. They are two separate entities. Sometimes they interrelate but it is seldom the case when one has a super QIAIF. They are not related at all and are absolutely two different investment vehicles. QIAIFs buy up the assets while section 110 companies buy up the financial debt. This is in relation to a different area. I gave the example of Cedarwood Real Estate, another foreign-owned QIAIF, which gets €2.65 million in rent every year from the Central Bank. That relates to just one of nine properties it owns. It pays no tax at all in Ireland because it is structured in this way. There are countless other examples of this sort of structure and they have nothing at all to do with section 110 companies. I am asking whether the Government will use the Finance Bill to close down this loophole, if one wants to use that term, or provision of Irish law which allows for economic activity in Ireland to go untaxed.