Mairéad Farrell (Galway West, Sinn Fein)
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I have some general questions on this section. Can the Minister explain the motivation for this change in the exemption of bona fide non-trading domestic transactions from the scope of transfer pricing and what the objective and operation of the provision is? How does this apply to companies that are using an orphan structure and that might nominally seem to be domestic non-trading entities but are, in fact, foreign-owned by using domestic trustees? As I am sure the Minister will be aware at this stage, asking questions about orphan structures is one of my hobby horses. I have an interest in that regard.