Eoghan Murphy (Dublin Bay South, Fine Gael)
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Revenue will not be doing deals upfront with companies. To say a deal might be done is to imply that there is not a consistent application of an assessment of what tax should be paid. It will consider what would be a reasonable commercial return based on the investment made and make an assessment based on that. It will have to take into account the different investments that have been made. Revenue is not worried that this gives scope for the avoidance of tax that should be owed. I am minded to take its advice on this. We have been examining it and I have read the Deputy’s questions and his proposed amendment and they have been discussed but this is seen to capture what the section intends to capture in terms of making sure artificially high interest payments are not being made under the section.