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

It is easy to get lost in the detail and to move away from the intention of the provision as per the amendment as drafted. The purpose is to ensure that an entity could not avoid the IREF taxable event by moving something between funds. For example, let us suppose someone tried to be clever and put a pension fund above an IREF to avoid payment because the pension fund was not liable to withholding tax. They would be unable to do that. That is the intent.