Seán Fleming (Laois-Offaly, Fianna Fail) | Oireachtas source

In an effort to be helpful, the Minister and the Department consistently keep the section 110 regime under review and make changes when issues are identified. If Revenue becomes aware of a particular issue, it brings it to the attention of the Department of Finance and changes are made.

For example, the Finance Act 2011 made a change in respect of profit participation notes. The 2016 Act made changes to the section 110 regime to ensure profits derived from Irish land and buildings were subject to tax in Ireland. The 2019 Finance Act strengthened the 2011 anti-avoidance rules to ensure that they are effective and operate as intended.

While no report has been produced, nobody has the exact figures. These are three specific issues which Revenue felt needed to be deal with. There might be a forum to have a broader discussion on the section 110 mechanism other than here. One can hang the hat of looking for information on those three changes and ask what the rationale behind them was. It might open up the debate on that matter. There might be a mechanism other than the Finance Bill during the course of the year to explore this topic further.