Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

These Government amendments relate to section 21 of the Bill and deal with section 110 companies. The work of Revenue and Department of Finance officials in the past 12 months on this issue must be acknowledged. There has been a lot of analysis. The amendments primarily seek to ensure there will be no unintended contamination of what is a legitimate aspect of the financial services industry, specifically, securitisation. There is a need to shore up that aspect to ensure there will be no unintended contamination. Section 22 is even more complex and perhaps more controversial.

Overall, I welcome what is contained in section 21 and the amendments tabled by the Minister. There will always be a game of cat and mouse between the most intelligent and well remunerated tax practitioners advising funds and the bright people in Revenue and the Department of Finance. The Minister has made a commitment to close gaps that may emerge and loopholes that may be identified. It could be along the lines of the way in which section 110 and profit participating notes were used to effectively sweep all of the profits out of the section 110 companies. That is not the way section 110 was intended to be used when it was first introduced for use in the financial services industry. Section 22 is even more substantive. These are positive changes which I welcome.

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