Mr. Seamus Coffey:

No, I do not believe it is retrospective taxation. It does not change the amount of capital allowances that are available. The total quantum of capital allowances remains the same. All that changes is the amount that can be claimed in future years. That is limited to 80% of the taxable income that is earned. It is not retrospective taxation. More taxation is not being collected from the investment by reducing the limit because the amount of the capital allowance remains the same. Those who would suggest that it is a retrospective change should be questioned as to why they think the tax would not be collected in the future. A retrospective change would imply that more tax was being collected and when the capital allowances run out we would not be collecting the money. In my view, the only way there can be a retrospective change is if more tax is being collected from the investment decision. The internal rate of return on those investments remains the same, whether there is an 80% cap or a 100% cap. If more tax is collected with the 80% cap it does suggest that the tax was not going to be collected when the capital allowances run out.