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

Let me explain the purpose of the amendment. The gross roll-up regime is time-capped for Irish resident investors. That means that when there is distribution, the investor will pay tax at that point in time at the marginal rate. Currently, for a non-resident investor, there is no distribution in the seven or eight-year period; therefore, there is no taxable event and, effectively, no tax may be paid. We are trying to capture this because of what is known to be happening here. We want to bring forward a withholding tax. There are different provisions to make sure, regardless of what tax treaties are in place, the amount or percentage cannot be deducted and that if one has a controlling interest in an IREF, one will not be able to avoid paying the withholding tax.