Results 8,901-8,920 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: Section 739K(1) contains the definitions that apply to Irish real estate funds, IREFs. The primary definitions that have been updated in this section include "IREF assets" and "IREF business" and these are being extended to include "specified mortgages" under section 110 of the Taxes Consolidation Act 1997 and shares in real estate investment trusts, REITs. The broadening of the definitions...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: What we are trying to do with the amendment is capture non-resident investors who are investing in property and not paying tax. It is a taxing right of the State to tax property. Irish residents and non-residents are treated differently in so far as the level of taxation they might pay is concerned and that is right and fair because people are resident in the State and see a return on the...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: If a hotel group - a trading company - purchases and sells a hotel, capital gains tax will be due. However, as it stands, it is not due on funds. That is what we are bringing forward where assets are disposed of within five years.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: If a hotel group manages five hotels, is a hotel group and a trading company within Ireland; it comes under all of the typical resident taxation laws that apply. What has been identified is the situation where funds have made a particular play as far as property or property-backed assets are concerned and trying to capture it as a taxable event. The gross roll-up regime is the mechanism by...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: That is as an Irish resident, but who we are trying to capture is the non-resident who would not have been liable to CGT.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: As it stands, if one is an Irish investor and the distribution is made at the seven or eight year mark, one will pay at a rate of 41% on the distribution. If one is non-resident, one will not pay anything. The set-up on an investment in a property abroad depends on the arrangements made between the two jurisdictions. It is my understanding that the Deputy's example in New York would not...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It is.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: An Irish non-resident investor investing in a foreign jurisdiction, yes.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Does the Deputy mean resident in Ireland?
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: We are not talking about an Irish resident investing in a New York property. The example the Deputy has just given relates to the different layers of taxation that apply.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Okay.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: What we are trying to address is how we can get the appropriate amount of taxation from a fund where previously no taxes were paid on these activities. That is the purpose of the amendment and what we are trying to capture. An Irish resident would avail of the gross roll-up regime. In that regard, we are going to say it will be a chargeable event and that an exit tax will have to be paid....
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: For non-resident investors in a fund.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I do not think that is accurate. I think what an Irish investor is liable for currently is tax at 41% on distribution.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Are we talking about investing through a fund and not trading like a company?
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: We are not talking about a company but about a fund.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The amendment is seeking to place a charge on a non-resident investor. It is not making a change in terms of what might be due for an Irish resident investor.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: If they invest through a fund.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I do not think that is accurate.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The fund does not pay tax. The fund is tax neutral.