Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

The profit participating note is the key thing. This was the mechanism that was being used to sweep profits out of a company and the pillar on which this lawful tax avoidance was built. If the profits are now to be left there and to be properly taxable in accordance with Irish law, what tax rate will apply? There are three types of gains: the interest received by the fund, the capital gain on any disposal and capital repayments in excess of the amount paid by the fund for a loan. Is this to be trading income at 12.5% or non-trading income at 25%?