Mairéad Farrell (Galway West, Sinn Fein)
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I move amendment No. 153:

In page 66, between lines 2 and 3, to insert the following:

“PART 6

REPORTS

Report on hybrid mismatches (use of hybrid financial instruments) 55.The Minister shall, within 6 months of the passing of this Act, report the total number of yearly transactions that used hybrid financial instruments (profit participating notes/loans) and their total annual value (in nominal terms).”.

This relates to hybrid mismatches, particularly in instances of double non-taxation, which are of concern to the EU and the OECD. The amendment is designed to shore up the laws on hybrid mismatches. However, I am concerned that special purpose vehicles, SPVs, which I have mentioned throughout this debate, could use hybrid financial instruments to refer to profit participating loans, which will not be captured in this hybrid mismatch. That is why I have tabled the amendment.