Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

I move amendment No. 44:

In page 39, between lines 7 and 8, to insert the following:

"22. The Minister shall within 3 months of the passing of this Act, prepare and lay before Dáil Éireann a report in relation to the tax neutral status available to Section 110 companies that are involved in loan origination businesses, which examines removing this tax neutral status."

This amendment relates to another report on the tax-neutral status available to section 110 companies which are involved in the loan origination business in order to examine the removal of this status. In the Finance Bill 2016, changes were made to the section 110 regime. We saw these changes brought in and they were welcome, but there was a carve-out built in with regard to non-bank landers involved in the loan origination business. This means that non-bank lenders with hundreds of millions lent to Irish businesses, and with profits in the millions, could continue to pay tax of as little as €250 per year.

Let us look at an example of one such lender. BlueBay has issued debt to the fast food business, Abrakebabra, and the Mater Private Hospital, among others. From looking at its lending rates online, I assume that the blended average rate of its loan book is in excess of 6%. That would mean profits of well over €9 million in 2016 where BlueBay had €160 million loaned out, a blended rate of 6% and profits of €9 million. Does the Minister know how much tax it paid? It paid €250 on profits of €9 million. That is not acceptable, and it is not fair in light of everything we have seen. We talk about tax avoidance, the Paradise Papers and so on, and politicians will tut-tut at this and tut-tut at that. This is about really smart accountants trying to find loopholes. The Minister is engineering the loopholes into the Finance Bill. This was done deliberately last year. How can the Minister stand over a company which loaned out €160 million and made in the region of €9 million profit on those loans to Irish businesses, including the Mater Private Hospital and Abrakebabra as examples, paying only €250 tax on its profits?