Richard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance) | Oireachtas source

That answer is in no way satisfactory. We do not have to hand the Minister's initial note in order to go through it. This is the problem which I raised yesterday and Deputy Burton has raised it again. We have amendments before us, which may be very substantial, that were not in the initial draft Bill but could have significant implications and we have not been given a proper explanatory note.

The Minister referred to the tax-neutral status of these section 110 companies and his concern that if this amendment is not made, there could be retrospection. The Minister has said that he does not like retrospection but we do when it relates to section 110 companies. If the Minister is saying that by not changing it that there is a possibility of retrospectively capturing some tax from section 110 companies, which have got away with murder and have avoided tax to an extent that the Minister cannot give us figures - he has never given us figures on the amounts of tax foregone as a result of the section 110 loophole - then I say to him he should leave it as it is. Then we can see how we might use the current tax code to get some of the foregone tax lost in recent years as a result of this scandalous section 110 tax-neutral structure, which allows these vulture funds to pay no tax on enormous profits and capital gains. I refer to shares on property, income gains and the capital gains they might make on those shares on Irish property, which has shot up in value, as well as in respect of the rental income generated from it.

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