Results 8,861-8,880 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: 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”.

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. 81: In page 35, line 3, to delete “a warehousing” and substitute “may provide for a warehousing”.

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. 82: In page 35, line 6, to delete “investment” and substitute “provide for investment”.

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. 83: In page 35, line 37, after “security” to insert “to a borrower that has a specified property business”.

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. 84: In page 36, line 13, to delete “or”.