Stephen Donnelly (Wicklow, Social Democrats) | Oireachtas source

Absolutely. Based on what they have been doing, I am not terribly concerned about the tax privacy rights of vulture funds in Ireland but I do take the Minister of State's point. I will suggest one other fix for this. I cannot find anywhere in the proposed amendment that explicitly breaks any link between the vulture fund and the lender of the extra money. At the moment they lend money to themselves. The idea is that the loan is supposed to be an arm's length loan. In reality these companies have corporate structures all over the world in that, say, one can set up a fund in the Cayman Islands, loan to a company in Luxembourg which then lends to another company in Luxembourg, which buys an investment vehicle in Ireland which buys the loans and so on. Nobody sees the link between the loan and the vulture fund. As part of an anti-avoidance measure perhaps the Minister of State would take into consideration that there can be no link, domestically or internationally, between the lender and the vulture fund. Right now they are lending money to themselves and this is what we are trying to break.