Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

I thank the Minister for that. However, the core question was on the policy rationale and how the tax has applied up to now. My understanding is that there has been conflict or that tax practitioners would have had an issue with this and would have challenged the Revenue’s interpretation, which, in fairness, was not the Revenue’s interpretation all along but was one which evolved, whereby lump sums generated outside would be treated as capital and would therefore not be taxable. What I am trying to understand is whether this ensures that a portion of the lump sum, which is the portion above €200,000, would be taxable for the first time. Has there been a decision by the Tax Appeals Commission in respect of a challenge to this?