Oireachtas Joint and Select Committees

Wednesday, 1 June 2022

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach

Use of Section 110 by Russian Firms: Dr. Jim Stewart

Photo of Pearse DohertyPearse Doherty (Donegal, Sinn Fein) | Oireachtas source

As Dr. Stewart said, these section 110 special purpose vehicles do not employ anyone. There is no contribution to income tax, PRSI or USC, nor do they pay any corporation tax because their interest payments can be used to write down taxable profits. They do not pay any dividend withholding tax, capital gains tax or stamp duty. In an Irish context, the real beneficiaries are the professional service firms, whose fees are also tax deductible. Is there an argument that section 110 firms really function as taxpayer subsidies to a select group of professional services firms operating in the IFSC?

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