Richard Bruton (Dublin North Central, Fine Gael)
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Question 361: To ask the Minister for Finance the circumstances in which an SSIA holder would be liable for 23% of the entire moneys in the scheme due to recourse to borrowings by a person to fund any part of the investment; and if he will make a statement on the matter. [10406/05]

Brian Cowen (Laois-Offaly, Fianna Fail)
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The SSIA scheme introduced by the Government in 2001 contains conditions which each SSIA account holder must comply with when opening, maintaining, ceasing or maturing their accounts. These conditions are contained in Part 38A of the Taxes Consolidation Act 1997 as inserted by section 33 of the Finance Act 2001.

One of these conditions is that the subscriptions made to the SSIA by the SSIA holder must be funded from funds available to the holder or both the holder and the spouse of the holder without recourse to borrowing. Where this condition is not complied with, the SSIA is treated as ceasing and the account thereafter shall not be an SSIA and the value of all assets in the account is liable to tax at 23%.