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

If a hotel group manages five hotels, is a hotel group and a trading company within Ireland; it comes under all of the typical resident taxation laws that apply. What has been identified is the situation where funds have made a particular play as far as property or property-backed assets are concerned and trying to capture it as a taxable event. The gross roll-up regime is the mechanism by which investment funds are not subject to taxation within the fund in so far as allowing the fund to grow is concerned and only taxing when there is an exit from the fund where a taxable event occurs. This has been explained before at the committee. That is where we include the withholding tax in the amendment. That would capture it in so far as the fund was concerned. That is how the fund will grow without deductions for taxation.