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

First, the use of section 110 in aviation financing is relatively recent. That is not one of the reasons section 110 was created. It was created to allow, for example, a bank to pool its debt and sell it as cash flow to a third party. There are benefits to doing that other than trying to avoid taxation. It would be done to diversify risk, to reinvest or to free up space in terms of capital requirements. There are many reasons an Irish bank would want to use a section 110 vehicle or to securitise in this way. It does not speak to tax avoidance.