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

A regulated commercial bank could issue a higher rate of interest if it sees it as a riskier venture, with a higher rate of return. It still requires an interpretation by Revenue as to what would be the best applicable rate to make. we do not want the kind of attitude that the Deputy fears. It is not the intention of the section. In this instance Revenue would be using the banks as their comparator as that would be the thing to do. Revenue is not going to allow the kind of comparator that the Deputy has outlined.