Stephen Donnelly (Wicklow, Social Democrats)
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I thank the Minister of State. If the Minister of State does not mind and bears with me, I will run through the loopholes. The first loophole the advisers are telling the vulture funds they will be able to use to continue to avoid paying taxes in spite of, in fairness to the Government, very good efforts to try to shut down this behaviour, is they are bullish their existing loan arrangements will be allowed to continue. As context, the way vulture funds avoid paying any tax here is they set up loans from abroad to themselves via various mechanisms. These are high interest loans known as profit participating notes, PPNs. Vulture funds here collect an awful lot of money through rent, capital repayments and interest payments. They accumulate significant profits and these PPNs, which are loans to themselves from abroad, are adjusted to a variable height whereby when the interest on them is paid no profit is left to be taxed in the country. The lawyers and accountants are telling their clients the Government will try to change this, which is what we are trying to do here, but that existing arrangements are rock solid and the Government will not be able to change them. Will the Minister of State confirm the proposed changes to the interest rates the vulture funds will be allowed to pay will definitely apply to existing loan arrangements for the vulture funds?