Eoghan Murphy (Dublin Bay South, Fine Gael) | Oireachtas source

Loan originations involve the section 110 company fronting for a foreign bank and either lending directly to a larger, more sophisticated borrower or immediately issuing newly made loans to smaller borrowers from the foreign bank. Provided the foreign bank is established in one of the countries with which we have signed a double tax agreement, no Irish tax would have arisen on its interest income had it lent directly to the Irish borrowers. As the original creditor, there can be no taxable capital gain on any subsequent sale of the loans.