Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

I move amendment No. 41:

In page 41, between lines 35 and 36, to insert the following:“25. The Minister shall, within six months of the passing of this Act, prepare and lay before Dáil Éireann a report on the tax paid in 2016 by companies that act as loan originators in the State and avail of section 110 status.”.

The amendment deals with the issue of the section 110 regime that was introduced. A carve-out was built in regarding non-bank lenders that were involved in loan origination business, meaning that non-bank lenders with hundreds of millions lent to Irish businesses and with profits in the millions could continue to pay as little tax as €250 per annum. BlueBay Ireland is one of the beneficiaries of this treatment. It has lent out more than €160 million across the State. BlueBay has issued debt to, among many others, the fast food restaurant company Abrakebabra and the Mater Private Hospital. I assume, on looking at its lending rates, the blended average of the loan book is in the region of 6%. This would mean profits in the millions in 2016. Looking at its accounts, which can be seen by anyone who wants to look at them, we see the total sum it paid in tax on those millions in profits was €250. Irish banks will not pay tax for 20 years because of the losses they have carried forward, but these non-bank lenders are not paying tax either. There are other sweetheart deals in respect of some multinationals that we discussed on previous amendments but this was supposed to be dealt with when we dealt with the section 110s in last year's Finance Bill. This whole section, in the context of section 110, is dodgy, and the evidence suggests it needs further tidying up, to say the least. It is incredible that a foreign bank can set up a section 110 company, and we have examples of this. That company then lends into this State hundreds of millions of euro and makes profits on that lending and, because it is in this type of vehicle, no tax is payable. BlueBay is not unique in this regard. There are other such companies that pay as little as €250 in tax. I imagine the Minister will take to his feet and, without naming the company, present words to the House that will somehow justify that a company recording millions of euro in profit pays €250 in tax, yet he says this State is not facilitating State-sponsored tax avoidance. That is exactly what this is.

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