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Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I welcome the Minister and thank his officials both from Revenue and the Department in assisting me and my party in preparing our alternative budget. I know that this is the first time the Minister has appeared before the committee. I look forward to him enlightening us when he has made up his mind whether to appear before the Committee of Public Accounts. I would like to get into some...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: We are aware that there is a Department of Finance paper which states phasing out the USC would be of little or no benefit to low and middle-income earners.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I accept that, but I have sat at tables such as this and questioned other Ministers who wrecked the economy because they cut taxes to an unsustainable level and relied on property-related taxes. Corporation tax receipts are now in excess of the amount produced by property-related taxes at the time. The responsibility of the committee is to ensure that, regardless of our own political or...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I am not saying anything that is different from what the Minister and the Taoiseach have said. I think everybody accepts that political decisions made by Ministers at the time led to the economy going off the cliff.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: You will get your opportunity.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I did ask it.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I asked if the Minister had any evidence within the Department and he does not. I want to ask the representative of the Revenue Commissioners about section 110. The Government's amendment will allow section 110 companies to mark to market. Is it Revenue's view that this has to be allowed such that capital gains accrued by such companies until 5 September will not be taxable?

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: Sorry, this is to the Revenue Commissioners.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I am directing it at the Revenue Commissioners.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I am not questioning the rate. In the opening statement, it was stated that the Revenue advises in regard to loopholes, avoidance and so on. Is it the Revenue's view that the loophole, as we will want to call it, in terms of section 110 cannot be retrospective and that one has to allow for the mark to market opening?

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: This is not retrospective taxation. It is allowing the Revenue to mark to market. It is as if we were to increase capital gains tax in this year's budget, in which case we would not say that any gain accrued in terms of an asset could be written off.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: The Revenue Commissioners issued two Revenue opinions to section 110 companies in regard to property in 2012. As such, the Revenue Commissioners were aware that section 110 companies were involved in property despite what we hear about this being an unintended consequence.

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I move on to the funds which are actually taking over the property as opposed to the financial interest. I refer to the qualified investment funds. Does the Revenue agree that qualified investor, alternative investment funds are the vehicle of choice for buying up commercial assets in the State?

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: These are public companies and we can look at their accounts. For example, Kennedy Wilson has €1 billion of assets in the State and made €26 million in profit in the first six months of the year while paying no tax in the country because it is structured as a qualified investor, alternative investment fund, which has nothing to do with section 110. Is the Revenue aware of...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: If one looks at some of the public accounts of these companies, Kennedy Wilson for example, one sees reference to withholding tax on British assets of 20% and on Spanish assets of 25% and it will boldly state that there is no tax on their Irish assets. In Kennedy Wilson's case that is assets of €1 billion and rental income of €26 million in the first six months of the year. Is...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: As a point of interest, section 110 companies, which are what Deputy Donnelly has raised with particular reference to loopholes and the proposed amendment, have nothing at all to do with qualified investor funds. They are two separate entities. Sometimes they interrelate but it is seldom the case when one has a super QIAIF. They are not related at all and are absolutely two different...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: We certainly will. Can the Revenue indicate how many companies operate under the double-Irish tax structure currently? I am not looking for the identities of the companies. While it has been closed to new entrants, the Government decided in its wisdom to allow existing users of the facility to use it up to 2020. I am curious as to whether if we were to bring the date forward there would...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: If the shut-off date was brought forward, would there be an increase in revenue?

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I direct the next question to the Minister. We know the position of the Government on water and will not rehash it in terms of the commission and a vote in the Dáil at a certain stage. I am curious about the fiscal space, however, given the uncertainty of that vote in the Dáil and whether water charges will be abolished or suspended indefinitely. They are currently suspended to...

Committee on Budgetary Oversight: Revenue Raising Proposals: Minister for Finance and Revenue Commissioners (20 Sep 2016)

Pearse Doherty: I will finish up soon. The Government has come up with the idea of a help-to-buy scheme. It sounds great - the slogan sounds great anyway. There is a lot of concern, which I share, that it will increase property prices. We know that 35% of new loans can be issued outside the Central Bank's strict loan-to-income and loan-to-deposit ratios. Can the Minister enlighten us as to what he...

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