Eoghan Murphy (Dublin Bay South, Fine Gael) | Oireachtas source

The benefit of this section, in the context of the debate we had with Deputy Pearse Doherty on Committee Stage, is to capture a particular type of tax planning that was not captured in the previous version of the amendment, but which is captured now. That is the benefit of this section and that is what we are debating now.

To speak to Deputy Donnelly's questions on the distribution of gains, IREFs will apply withholding tax on gains distributed within five years but where an IREF is in the control of a particular investor, as per the discussion we had around Deputy Doherty's amendment, in so far as the 10% threshold is concerned and in terms of having a controlling interest in the fund, that is where the withholding tax will apply on gains, as per the amendment to the section.

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