Catherine Murphy (Kildare North, Social Democrats) | Oireachtas source

I thank the witness for the update and following through on some of the questions we asked last week. I am interested in the section on transfer pricing. That comes out of the report, Review of Ireland’s Corporation Tax Code, by Mr. Seamus Coffey. If transfer pricing were to be extended to non-trading transactions that would include transfer pricing examination of matters such as renting property, how would that apply in respect of real estate investment trusts, REITs? The witness has described withholding tax to us and the tax being liable.

I will put an example. If 80% of shareholders were in one of the other European countries, essentially the tax liability, with the exception of the withholding tax liability, is in the country of their origin. Would this recommendation in the Coffey report have any bearing on where the tax liability might fall? We are seeing, in effect, property become mobile for the first time. The understanding was that property was the one thing that could be taxed in one location and was not mobile. Where would that intersect with these real estate investment trusts, if at all?