Results 8,761-8,780 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. 73:In page 60, line 26, to delete “ceases to be a” and substitute “becomes a”.
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: I move amendment No. 74:In page 61, line 11, to delete “ceases to be a” and substitute “becomes a”.
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: I move amendment No. 75:In page 62, to delete line 10 and substitute “Declaration of Credit Unions”.
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: I move amendment No. 76:In page 62, to delete line 26 and substitute “Declaration of qualifying company”.
- 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: The benefit here is a new level of taxation on non-resident investors that did not currently exist through the withholding tax. That is the benefit. It was not taxed previously, but it is taxed now.
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: The benefit of this section, in the context of the debate we had with Deputy Pearse Doherty on Committee Stage, is to capture a particular type of tax planning that was not captured in the previous version of the amendment, but which is captured now. That is the benefit of this section and that is what we are debating now. To speak to Deputy Donnelly's questions on the distribution of...
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: I move amendment No. 50:In page 46, line 16, to delete “the IREF profits” and substitute “the IREF profits, including any retained IREF profits,”.
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: This amendment tightens the drafting around specified persons to confirm that the NTMA and exempt unit trusts will not be subject to this 20% withholding tax, if they hold units in an IREF. This is on the basis that both the NTMA and exempt unit trusts are exempt from tax generally. The amendment also provides that no IREF withholding tax will apply to payments to investment limited...
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: I move amendment No. 51:In page 46, between lines 23 and 24, to insert the following: “ ‘retained IREF profits’ means the portion of the retained profits of the investment undertaking attributable to the IREF profits, and where those profits arose in an accounting period which commenced prior to 1 January 2017 or 20 October 2016, as the case may be, those profits shall be...
- Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)
Eoghan Murphy: I move amendment No. 52:In page 46, line 26, to delete “subsection (6), (7)” and substitute “subsection (6) (other than paragraphs (cc), (e), and (kb)), (7)”.
- 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.