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

I do not know if it is fair to say that. Obviously the relationship between the section 110 and what would become an IREF, what at the moment is an ICAV or a QIF, not everyone will be using a relationship there at all, and some will, so in certain instances one will not be able necessarily to disaggregate out the two as a result of that relationship. So, for example, where a section 110 might acquire the loan it might move on the asset and the asset might move into the fund. I do not know how one could potentially disaggregate out those two figures.

Part of this speaks to the Deputy’s later amendment in terms of being able to understand exactly what the impact of the changes are and what that might mean for extra money coming into the tax base. The figure of €50 million has been extrapolated by Revenue, given the work it has done to date. I will have to see if we can get more detail on how that figure was arrived at for Report Stage, and if there is a disaggregation possible there between the two sections.