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

The figures that I have been given here were based on the work that Revenue did, as I read into the record. The figures are based on potential profits made on a sample of mortgages valued at circa €1 billion held by a number of section 110 companies that were examined. The results of the examination were then extrapolated to a potential mortgage book population of €20 billion. The key assumption that underlies the figure is that only normal trading reductions were allowable, such as interest charged at the normal third party market rates in calculating the taxable profits, that is, that no deduction for profit-participating notes would be availed of.

The amendment was published in September. It was redrafted and extended for inclusion in the Finance Bill to ensure the proposal was as targeted as possible, but it is also being included now with section 22 dealing with IREFs, as I stated, and the figure of €50 million does not take into account any potential behavioural changes following both amendments to section 110. That figure is for the section 110s and the funds. That is how that figure has been arrived at, looking at the potential of both so there is not a disaggregated figure.