Stephen Donnelly (Wicklow, Social Democrats) | Oireachtas source

Coming back to the ownership of QIAIFs and ICAVs, my understanding of the last-man-standing rule is that the tax liability passes to wherever the profits are realised and fully dispersed. Specifically, if there is an ICAV or QIAIF here which owns office blocks, hotels, apartment blocks or factories and that ICAV or QIAIF is in turn owned by an investment undertaking outside Ireland, will the withholding tax be paid to the Irish Exchequer or transfer under treaty on the assumption that it will be paid in the jurisdiction where the money stops moving? Luxembourg is usually the jurisdiction of choice because one can get one's profits out of there quite easily.

See this speech in context