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

The concern in drafting the amendment is that people might try to structure the relationship between funds or different investment vehicles in such a way as was as to avoid having to pay the withholding tax at the appropriate point. This measure serves to ensure, in so far as the list I read out is concerned, that any transfer between entities in that way or where there might be a parent or a company above or below the IREF, would not avoid the IREF chargeable event.