Results 6,781-6,800 of 15,555 for speaker:Eoghan Murphy

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 53:In page 46, line 29, to delete “subject to 739M” and substitute “subject to section 739M”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 54:In page 47, to delete lines 35 to 37 and substitute “B is the retained IREF profits,”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 55:In page 47, lines 38 and 39, to delete all words from and including “excluding” in line 38 down to and including line 39.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 56:In page 48, lines 38 and 39, to delete “the IREF is a personal portfolio IREF in respect of any of the unit holders” and substitute “subject to section 739N, the IREF is a personal portfolio IREF in respect of the unit holder". I propose to take amendments Nos. 56 and 57 together. Amendment No. 56 does two things. First, it deletes section 739N...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: In reply to Deputy Donnelly, the last-man-standing rule will apply if it comes to people trying to make those distributions between funds. In trying to avoid withholding tax by simply placing an exempt fund above or below the existing fund, one would be caught by the anti-avoidance measures in that instance. The QIAIF or the ICAV will not be exempt if it is held by another fund in that...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I am informed that if it is a widely-held fund, the withholding tax will not apply if the fund is distributing between Ireland and Luxembourg.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: If it is widely held.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: That is the opposite of what we were doing within Deputy Doherty's amendment in terms of the control of the fund.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: Amendment No. 47 will capture where the control of the fund is.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: It speaks also to Deputy Burton's point. Amendment No. 47 captures it.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: That is correct. In so far as Deputy Burton is concerned, amendment No. 47 captures the hypothetical case she set out.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 57:In page 49, to delete lines 8 to 24 and substitute the following:“Anti-avoidance: multiple funds further measures 739N. (1) Where—(a) an IREF would otherwise be a personal portfolio IREF in accordance with section 739M(3)(a), and (b) the scheme, undertaking or company, as the case may be, in respect of which it is a personal portfolio IREF would not be...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 58:In page 50, line 5, to delete “this Chapter” and substitute “paragraph (b)”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 59:In page 51, line 21, to delete “otherwise”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 60:In page 51, line 29, to delete “, repayment of IREF withholding tax” and substitute “and subject to section 739T, repayment of withholding tax”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 61:In page 52, lines 2 and 3, to delete “shall be entitled to make a claim” and substitute the following:“shall be entitled to a refund of withholding tax as if the units concerned were directly held and to make a claim”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 62:In page 52, between lines 6 and 7, to insert the following:“(4) For the purposes of section 865(2) the return made by the IREF under section 739R shall be deemed to be a return made by the unit holder for the purposes of an assessment to tax.”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 63:In page 53, lines 10 and 11, to delete “, in respect of a specified person”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 64:In page 56, to delete lines 1 and 2 and substitute the following:“(ii) all of the shares issued are ordinary shares with equal rights, and”.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Eoghan Murphy: I move amendment No. 65:In page 56, to delete lines 17 to 21 and substitute the following:“(a) the investment undertaking shall be deemed to have disposed of all assets in use for the purposes of the transferred business for the value at which they are carried in the accounts,”. Amendments Nos. 65 and 66 are technical amendments to correct a drafting error in the original Bill....