Mr. Niall Cody:

I will address section 110. This is a matter of public record because it has appeared in the newspapers as a result of requests under freedom of information, where Revenue was identifying issues in relation to section 110 and the use in the context of Irish property. Deputy Catherine Murphy mentioned earlier about real time. "Real time" in the context of business taxes for Revenue is at least 18 months after the event because of the way returns are filed and accounts are prepared. We started raising the issue when we saw evidence of Irish property in section 110 vehicles. We first had to do an analysis on it. Obviously Deputies and journalists have raised the issue as well. The Minister has now published draft legislation and has undertaken to bring forward further amendments in the Bill as published.

The use of charities in the context of section 110 is not about tax at all. It is about the use of a trust. The only type of trust available in Irish law is a charitable trust. The issue is, I understand, subject to inquiry by the charities regulator. Up to last year-----