Results 6,541-6,560 of 15,555 for speaker:Eoghan Murphy
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: My officials inform me that it is based on section 21 and section 22 and that while the section 22 amendment had not been published at the time, work was already under way on its scope in order that a calculation could be made on the back of the proposed amendment.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: That is absolutely crucial as far as our offering as an international financial services centre is concerned. It is a big part of what we do in the area of fund management administration. I think something like €2 trillion is administered through funds while a tiny percentage, 1% or 2%, is invested in Ireland itself. It is important we maintain this offering as part of our suite of...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: That is the case. I do not want to undermine the important work that has been done and discussing this publicly in the Oireachtas has been an important component of understanding what happens and ensuring our amendments are robust in dealing with tax avoidance. Revenue was looking at it before it began to be written about and it came to the Department with its concerns. My understanding is...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It will apply to any profits earned after 5 September 2016.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Yes.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Yes. The amendment as drafted addresses that in full.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The profit participating note would not have been taxed because section 110 companies were not treated as a trading company might have been. Under the changes proposed in this amendment, a non-resident investor will be subject to 25% tax when the distribution is made.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: A tax rate of 25% is paid by the section 110 company.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The tax is paid on all of the profits.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: They are profits.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Yes. That is the intention of the amendment.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Yes, that is correct.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The intention of the amendment is that listing is not enough to get around what is proposed.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It can, but it will not avoid tax by doing that because tax will be chargeable on its operation as a QIAIF or an Irish collective asset-management vehicle, ICAV, as it becomes an IREF.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Historical profits already covered by section 110 would be triggered at that point. They would be captured there.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: If the section 110 company steps into an ICAV, it is essentially selling itself into the fund, so the profits will be captured in terms of a taxation event.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: No. It is a taxable event when a section 110 company becomes a fund.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Funds can account for normal daily trading deductions only. Then, 25% would be taken from the €100 million in tax.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I move amendment No. 79: In page 34, line 35, to delete “of a relevant Member State” and substitute “of the State or a relevant Member State”.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I move amendment No. 80: In page 35, line 2, to delete “provide for”.