Stephen Donnelly (Wicklow, Social Democrats) | Oireachtas source

It can also be done without using section 110. Section 110 vehicles only exist in Ireland but banks all over the world do what the Minister of State is speaking about. The tax-free box that is a section 110 vehicle does not exist in the US, France or Germany. It exists here as a global securitisation play because there needed to be an aggregator that could bring profits into the country and out of the country that we did not touch because they did not come from here. In terms of any bank creating a security from its mortgages and taking it off-balance sheet and, therefore, diversifying its risks, banks do that all over the world, but they pay taxes on it.