Results 8,961-8,980 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 what we are trying to capture with the amendments. They are drafted in this way to make sure we get the withholding tax from these funds. This would not have applied previously. We also want to get capital gains tax from them if they dispose of these funds, or the assets in them, within a five-year period.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The purpose of this amendment is to introduce a withholding tax to tax these entities and funds.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: A deemed-day taxable event or exit tax chargeable event will apply to Irish-resident investors every year. At that point, an individual investor would pay 41% tax on the dividend paid.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I think I understand the point of view from which the Deputy is approaching this matter. We have to be careful to strike a balance when we are moving to address the leaking of tax out of the Irish State, or the Irish Exchequer, as a result of the operation of a few funds. We are probably talking about approximately 1% of all funds being administratively managed through the Irish State....
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I am not sure. I am not aware of how they could make a capital gain off the back of-----
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I can get a proper note on this in advance of Report Stage, but my understanding is that one would not be able to convert retained profits into a new capital investment because that would be seen as a gain that might be liable to tax.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Yes, I will get confirmation on it.
- 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 it is possible, but I will get a proper note on it so we can be clear on it.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: I will get clarity on that before Report Stage.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: The IREF regime will not apply to certain categories of investment funds that fall within the definition of "investment undertakings" in section 739B. The first of these is a unit trust scheme that is or is deemed to be a currently authorised unit trust scheme under the Unit Trusts Act 1990 but not special investment schemes as defined in section 737 or exempt unit trusts as defined in...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: That does not mean there is an exemption for all of them. There is a last man standing principle here. If there is a transfer between investment undertakings, the final transfer is when the tax is applied. I think the officials went through this in some detail at the technical briefing. If there is a transfer between investment undertakings, withholding tax will not be applied, but when...
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: It is when the final investment undertaking has occurred, at the point of the final transfer. That is when we have a taxable event under section 22 of the IREF legislation.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: We are talking about the transfer between two holdings.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: We are talking about the transfer between two entities and then the distribution that would take place. Withholding tax would apply then.
- Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2016: Committee Stage (Resumed) (15 Nov 2016)
Eoghan Murphy: Any transfer that might occur between two of the entities, as I listed them, which would be deemed to have come under an IREF taxable event would take place at the last point of the investment being transferred and 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: No, they are IREFs. The point of the section is to make them IREFs if they are involved in property.
- 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.