Ms Laurena Leacy:

On the first question on group relief, group relief is under head 4. It is designed to maximise the return of contribution to the State and avoid a situation where a company may have other entities and use group relief to lower contributions. That adjustment will increase the contribution. It is an anti-avoidance measure. That will not result in a reduction to the contribution.

On introducing a ceiling to capital expenditure, when we considered capital expenditure we had discussions with tax experts, including the Revenue Commissioners.

In keeping with tax principles, there were two conditions put on capital expenditure, so it is not just any capital expenditure can be deducted. It must be allowable for capital allowances and claimed with normal corporation tax and tangible assets for the purpose of activities for which the contribution relates in Ireland or within the maritime jurisdiction area and within use for a period of at least five years. This was to avoid situations where companies might buy assets or form other ways to artificially lower what would have been their contribution. We have taken measures through those two conditions to ensure that the capital expenditure deducted is fair and related to the activities for which the temporary solidarity contribution, TSC, applies. However, I take the Senator’s point about a ceiling.