Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

While I appreciate this is work in progress, I would like to know what principle will be applied. I refer again to the case of Kennedy Wilson because it is a good example of a fund with properties in different jurisdiction. The company's accounts note that it pays income tax of 25% on profits generated in its Spanish subsidiaries and 20% on profits generated in its UK subsidiaries. Dividends paid to non-residents from assets are taxed at a rate of 26.3% in Germany and 30% in France. That is the position in other jurisdictions. While I appreciate that the fund industry is a major employer, this issue is the abuse of certain funds, rather than the industry. Will the Minister apply the principle that income derived from assets in this State should be taxable in this State regardless of whether the investors in the fund are foreign or domestic? At this point, only domestic investors in a fund are taxed on revenue generated from assets in the State. Is the Department considering applying this principle? If so, the change would at least be in line with what we want to achieve. We would then need time to tease out how to achieve this outcome during the debates on the finance Bill.

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