Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

Can the Minister provide the background to this? This is obviously on the taxation of foreign retention arrangements and in particular regarding the lump sums. This brings into focus what many people could only dream of, that is, the idea of being able to draw down a lump sum of €0.5 million. It is interesting to note if somebody was in a position to draw down a lump sum, their tax liability on that amount under Irish tax law would only be €60,000. It just shows the situation of those high net wealth individuals and the pension planning that goes on. This section appears to bring into focus the tax treatment of foreign pension arrangements. Is it the case that it is disputed whether they are taxable at all in terms of the lump sums being accumulated in relation to foreign pension arrangements and that this section just brings clarity in that they are taxable in line with Irish pension arrangements? I understand there may have been appeals to the taxation commissioner on that in the past. Will the Minister outline the background and the rational for this section and the decision of any tax appeal in relation to this matter also?

Can the Minister also clarify whether, if somebody had both a foreign and a domestic pension arrangement, the upper limits would apply for both, that is, that the tax-free part of it would be €200,000 and the portion between €200,000 and €500,000 would be taxed at 20% and could not be claimed twice on a domestic pension or a foreign pension?