Stephen Donnelly (Wicklow, Social Democrats)
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The language is important. The Minister of State says Revenue will not do deals with individual companies. Revenue will do deals with individual companies. Revenue will make a ruling for each company on the interest rate it pays and that ruling will be kept secret. I do not think it will do deals as in anything inappropriate. I absolutely accept that Revenue will apply the legislation equally and fairly but the application will give each company a different interest rate and we will never know what those interest rates are.

I do not know what the solution is. I suggested that it is linked to a regulated commercial bank. If that was given to Revenue it could say the answer is 3.5% to 4%.

I ask that at least some form of surveillance be considered before Report Stage. It is my understanding that Revenue will do an individual deal with each company. I do not mean they are doing anything wrong in that regard, I define a deal as the agreement of a different interest rate for each company. In such circumstances no-one will ever get to see those interest rates. On the basis that this is mass tax avoidance in a way that was never intended or anticipated, and on the basis that there will be secret deals done by Revenue in every case - if they continue to use internal loans - there should be some mechanism where legislators, the media and the public can see the interest rates that have been agreed with each of these companies.