Mr. Gerry Howard:

I simply would not feel that we are, at this point in time, in a position to put any particular figure on it. We started working on this matter in November 2015 and identified an issue. We traditionally reserve the right to tax profits and gains from Irish property. We were just concerned that the section 110 vehicle was being used to get around that measure so we started looking at it as an issue. It would be too early, at this stage, to say what the implications, in terms of yield, are likely to be. We have done some initial reviews of the matter but there is insufficient information at this point in time to say what the likely impact of it is.

There will be deductions, as the Deputy has quite rightfully said, in terms of interest. Traditionally, interest has been allowed as a deduction as all expenses are in the calculation of profits.

It is a matter of fact as to how the provisions work out. Certainly, there are legitimate expenses being put through these vehicles that should, with the legislation as it is, continue to be allowable. Until that matter is finalised it would be very difficult to put any figure on what the likely tax scale is.