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

We are looking at this because the State retains taxing rights on Irish property. That is why we saw a tax leakage and we moved to correct it through the amendments.

I cannot see how another fund might be operating in a way. We retain taxing rights on trading activity within the State and Irish-sourced income. I cannot foresee how a fund would be operating and investing in Ireland in such a way that we could claim taxing rights other that the three areas to which I have referred.

A fund is used as a bridge between the investor and the investment; therefore, generally, tax is paid at the level of the investor when the investment is returned through a dividend or a distribution. An individual pays at the rate of 41%, a passive investor in a company at 25% and a corporation at 12.5%. That is how it is treated internationally. I do not see, therefore, how we could operate differently, other than the fact that we found this tax leakage in the property market and are moving to address it in the amendment.