Oireachtas Joint and Select Committees

Wednesday, 8 November 2017

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach

Finance Bill 2017: Committee Stage (Resumed)

10:00 am

Photo of Richard Boyd BarrettRichard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance) | Oireachtas source

When we are trying to get to the truth of these tax breaks which are given to corporations or property interests, it is always revealing to look at how they are touted by the consultancy and accountancy firms which do the work of getting these people in.

Their comments are very revealing. Our friends, PwC, in their document Irish Real Estate Investment Structures, say:

[There has been a] remarkable resurgence of interest in ... Irish real estate ... spearheaded by overseas investors [not little Irish pensioners trying to save up for their pension pots] and in particular by the hedge funds and private equity groups. Such investors are using the array of available ... structures ranging from QIAIFs to REITs to SPVs to mitigate or eliminate taxes that would otherwise arise on their real estate investments.

They go on to refer to REITs: "[N]on-resident investors are not liable to CGT [this is them touting these things again] on the disposal of REIT shares." The document states REITs are "not chargeable to tax in respect of ... property rental business or chargeable gains accruing on the disposal of assets". Regarding section 110 companies, it states, "While such entities are taxable at a rate of 25%, the taxable profits tend to be modest because of the use of tax efficient profit ... mechanisms such as interest ... on profit participating loans." It goes on and on. What PwC is touting is the fact that this is an array of structures which allows the mitigation or complete elimination of the profits extracted from the Irish property sector, much of them courtesy of NAMA, which flogged this property - our property - to these buyers in order for them to extract profit and pay no tax. This is the greatest scandal this State has seen in recent times. As if everything that happened in 2007 and 2008 and the cost that people paid were not bad enough, that then became the prelude to the vast unloading of property assets to foreign investors, hedge funds and so on, which then extract an absolutely enormous profit from this and pay no tax. Now-----

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