Eoghan Murphy (Dublin Bay South, Fine Gael)
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In so far as language such as "deal" is being used, this implies that special treatment is being given or secret arrangements are being made, and that is absolutely not the intention of this section. This has been identified and brought to light, publicly and correctly, and we are now moving to try and do something about it. It may just be a difficulty of language because I do not believe there is a difficulty of intent with regard to what the section aims to achieve. Regulated banks themselves can do mezzanine deals. An interpretation will always be required on the part of Revenue on what would be an appropriate rate. Revenue is satisfied that the language provided will allow it to do this. Given that there are so few companies working in this area the Deputy's suggestion of oversight to see what is being done would pose a risk of breaching tax payer confidentiality. This aspect can of course be looked at between now and Report Stage to see whether that could be achieved but we must be sensitive to the fact that there are so few players operating in this space.