Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

The company is meeting its tax commitments. I would not suggest otherwise. Last year, when the Oireachtas dealt with section 110, a carve-out for loan origination was clearly written into the Bill. These changes did not apply to loan origination. Therefore, these companies can still use section 110 vehicles to write down their tax liabilities. They have special purpose vehicles under section 110 which neutralise, or almost neutralise, their tax liabilities. Therefore, neither the Revenue Commissioners nor I would in any way suggest that Revenue is developing policy for tax avoidance. I have huge regard for the Revenue Commissioners. The accusation I made was about the Minister and his Government, not the Revenue Commissioners. Let us be clear - the Revenue Commissioners are not losing any tax on this because it has to apply the law and the law says that companies can use this vehicle in order to pay such low taxes.

We can talk about section 110, we can talk about special purpose vehicles and we can talk about loan origination, but my basic question is as follows. I gave BlueBay as an example. I know the Minister cannot talk about an individual company but its files are on record. It paid €250 in tax. It is involved with the State through the Irish Strategic Investment Fund. Cardinal Capital Group is using the exact same vehicle. It has not filed its returns yet, but it is likely that the same figure of €250 will appear. The key question is that if a company has loaned out €160 million, for example, at a rate of 6% and made profit of in the region of €9 million, how does the Minister for Finance stand over the fact that it only paid €250 in tax on that profit. Does tax avoidance not hurt us all?