Oireachtas Joint and Select Committees

Tuesday, 5 November 2019

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

Finance Bill 2019: Committee Stage

Photo of Paschal DonohoePaschal Donohoe (Dublin Central, Fine Gael) | Oireachtas source

I move amendment No. 50:

In page 60, line 28, to delete “subsection (1)” and substitute “subsection (2)”.

I am bringing forward several amendments to section 30 which introduces new ATAD-compliant anti-hybrid rules to Irish legislation. The majority of the amendments which I am proposing to the section correct drafting, cross-reference and typographical errors in the Bill, as initiated. The remaining amendments address two minor issues that were identified following publication of the Bill and which need to be amended in order for the legislation to operate as intended.

Amendment No. 61 clarifies the definition of "financing return" in order to ensure the legislation provides a clear definition and is consistent with the related definition of a financial instrument. Amendments Nos. 53 to 56, inclusive, relate to the application of anti-hybrid rules as they interact with worldwide systems of taxation.

The purpose of the new section 835AB being introduced in section 30 of the Bill, as initiated, is to ensure that the application of anti-hybrid rules does not give rise to a deemed hybrid mismatch where no mismatch occurs. The amendment corrects small errors in language that occurred during the drafting process and ensures that the provision is effective in respect of other worldwide tax systems internationally in addition to the Irish worldwide tax code.

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