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

Yes, it is the case that some tax practitioners have challenged the taxation of these arrangements. This change is to make completely clear what the situation is and to erase any doubt about it in the future. My officials inform me that there has not been a material ruling by the Tax Appeals Commission that has influenced what we are doing. The earlier part of the Deputy’s question is correct, in that there has been some dispute over this and we are making very clear and this would be taxed with this change.