Paschal Donohoe (Dublin Central, Fine Gael) | Oireachtas source

I do not need to be reminded of my role in respect of housing. I work as closely as possible with the Minister, Deputy Eoghan Murphy, to look at how to make new resources available and to ensure the appropriate policies are in place. Deputies will recall that amendments to the taxation of section 110 companies were made in the Finance Act 2016 specifically to address the issue of returns relating to Irish property. Section 110 companies can only hold certain qualifying assets and real property, such as land and buildings, that are not an asset that a qualifying company can hold. They can, however, hold loans and other financial assets that derive their value from Irish land and buildings.

The changes made in the Finance Act 2016 relate to the taxation of qualifying companies which held loans that derived their value from Irish land. The effect of these changes was to ensure that profits generated from Irish real estate remain within the charge to tax.

The Finance Act 2016 also provided for the introduction of a new Irish real estate fund regime which made changes to the way in which Irish funds which derive 25% or more of their value from Irish real estate are taxed. A new 20% withholding tax was introduced on distributions from these funds.

The Finance Act 2013 provided for the operation of real estate investment trusts, REITs, in Ireland. The function of the REIT framework, in common with other jurisdictions, is not to provide an overall tax exemption but rather to facilitate collective investment in rental property.

I have been aware of concerns about the level of activity of the institutional sector in the housing market. I refer the Deputy to data from the Residential Tenancies Board included in this year's tax strategy group, TSG, paper on corporation tax, which demonstrates that over 91% of landlords hold three or fewer tenancies. The 20 largest landlords in Ireland now account for 3% of total tenancies. It is unlikely that landlords accounting for such a small proportion of tenancies are significantly influencing rental prices in the overall market.

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