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

I will speak to the Deputy's final point first. That fear might stem from the original drafting of the amendment, which is not in the final draft. They will not be affected in the way that fear was expressed to the Deputy. It is not the case with the text of the amendment that we are debating today.

The Deputy is absolutely right when it comes to a stable investment environment. That is why, when looking at how best to go about this, the idea of the IREF was landed upon as being an identifiable and distinct thing as far as other funds are concerned. One can now see what it is, what it means to be in it and how one can qualify. That was seen as the best way to do it in order to maintain that stability into the future. Hence, that is also why we have what is basically a new section coming into the Bill, rather than minor amendments being made elsewhere.

It is not clear whether all of the 96 Irish funds that I mentioned will become IREFs. We have 96 Irish funds and there is approximately €10 billion in assets held between them. It might be the case that a smaller number of those funds hold a much more substantial proportion of the €10 billion. It remains to be seen just how many of the 96 end up becoming IREFs.

That will be dependent on the percentage of their holding.

The aim is not to distinguish between what an Irish fund and a foreign fund might be doing in terms of how they operate. It is to make the distinction in so far as Irish property being held by the fund is concerned and what that might mean. I touched upon this earlier. If someone is trying to structure his or her fund in such a way as to avoid the 25% threshold, he or she can be caught in so far as the reasonable-measure tax is concerned. That is there to ensure we will not be susceptible to people restructuring or developing a new structure to sidestep that percentage rule.

It was estimated that five years would be reasonable. It is the introduction of CGT to incentivise holding an asset for longer than five years. A period of five years was seen as an appropriate cut-off for the length of time for which CGT would be applicable. That is how we came to it.