Eoghan Murphy (Dublin Bay South, Fine Gael)
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What we are trying to address is how we can get the appropriate amount of taxation from a fund where previously no taxes were paid on these activities. That is the purpose of the amendment and what we are trying to capture. An Irish resident would avail of the gross roll-up regime. In that regard, we are going to say it will be a chargeable event and that an exit tax will have to be paid. It will be charged at a marginal rate for an investor as an individual or at a rate of 25% for a passive corporate investor. There is nothing applied to the non-resident investor. What we are trying to make sure, in so far as non-resident investors are investing in Irish property, is that there will be a tax liability, in terms of a withholding tax to be paid on distributions made to non-resident investors. We are also introducing the CGT charge where they dispose of the asset within five years. This is a policy decision to try to incentivise the holding of property by non-resident investors for longer than five years.