Results 6,661-6,680 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: It is complicated. To be honest, I am trying to figure it out myself on this side of the table. My understanding is that the purpose is that tax is not avoided.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The concern in drafting the amendment is that people might try to structure the relationship between funds or different investment vehicles in such a way as was as to avoid having to pay the withholding tax at the appropriate point. This measure serves to ensure, in so far as the list I read out is concerned, that any transfer between entities in that way or where there might be a parent or...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It is easy to get lost in the detail and to move away from the intention of the provision as per the amendment as drafted. The purpose is to ensure that an entity could not avoid the IREF taxable event by moving something between funds. For example, let us suppose someone tried to be clever and put a pension fund above an IREF to avoid payment because the pension fund was not liable to...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: If that is helpful I will do it.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: We are looking at this because the State retains taxing rights on Irish property. That is why we saw a tax leakage and we moved to correct it through the amendments. I cannot see how another fund might be operating in a way. We retain taxing rights on trading activity within the State and Irish-sourced income. I cannot foresee how a fund would be operating and investing in Ireland in...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The tax would be paid when the pension fund pays out to the investor, the pension holder.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: There is not going to be any change for pension funds with this amendment in this legislation.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: They are exempt.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: They are treated the same as pension funds.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It has changed in the past ten years in that the tax is now paid on exiting the fund. Is that not the change that has taken place across life assurance and pension funds and everything else?
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The pension funds were not taxed ten years ago.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: They pay tax on that capital.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Will the Deputy repeat that question please?
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It still is. That capital is still taxed.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: There will be no withholding tax in that scenario for a life assurance company but as they move the profits into the company they would pay corporation tax on that. Chapter 5 of Part 26 of the Taxes Consolidation Act 1997, deals with the taxation of the investment return on life assurance policies and policies in respect of capital redemption businesses, in so far as they are new basis...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The Deputy made two points about life assurance fund companies and the movements between them. The fund which is the policyholders' life assurance side of the business, will be able to roll up as per the roll-up regime in that fund and grow the fund in that way. There would be a different treatment for the shareholders, which is a separate part of the life insurance fund. It would be...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: They will pay tax on the profits. Essentially it is not normal corporation tax, but it is taxed.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The shareholder side does not distribute to the policyholder. Is that the taxable movement to which the Deputy refers? Which movement is the Deputy talking about?
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I do not want to get lost in the weeds about the tax between life assurance fund companies but it is important that we clarify what this amendment would do. There would not be a change as for life assurance funds and the way their tax position is treated.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Does the Deputy wish me to come back to-----