Róisín Shortall (Dublin North West, Social Democrats)
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215. To ask the Minister for Finance regarding special purpose vehicles set up to take advantage of the provisions of section 110 of the Taxes Consolidation Act 1997, as amended, the number of such special purpose vehicles known to the Revenue Commissioners; the number of forms S110 received by the Revenue Commissioners in each of the years 2010 to 2015; the number of such vehicles audited by the Revenue Commissioners in each of those years; the amount of value added tax refund in each of those years; the value of the underlying assets held in these vehicles which have been securitised; the number and grades of staff of the Revenue Commissioners engaged in the monitoring of securitisation, by grade, by proportion of time allocated to the work, by Revenue divisions in which they are located and by the number of meetings held between staff of the Revenue Commissioners and staff in the Financial Regulator's Office regarding policing compliance levels with Irish law by these companies. [46892/15]

Michael Noonan (Limerick City, Fine Gael)
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I am advised by the Revenue Commissioners that:

(1)  The number of Special Purpose Companies set up in accordance with section 110 of the Taxes Consolidation Act 1997 is 2,144.  This excludes companies whose tax registration subsequently ceased as the company has been liquidated.

(2)  The number of notifications received by Revenue  for each of the years 2010 to 2015 is as follows:

It should be noted that these numbers include a small number of companies that no longer trade and have been liquidated.

(3) Section 110 companies are assigned to the Financial Services (Banking) District in Revenue's Large Cases Division. A large number of financial services taxpayers additional to section 110 companies are assigned to that District. Statistics relating to audits and other risk interventions are not recorded by reference to the type of taxpayer subject to intervention. Accordingly, it is not possible to establish the number of section 110 companies audited during each of the years 2010 to 2015.

(4) The amount of Value Added Tax repayments made in each of the years 2010 to 2015 is as follows:

Given the timeframe to provide information, these figures are only in respect of tax registrations that were live as at 6 January 2016. VAT repaid to section 110 companies whose tax registration ceased between 2010 and 2015 is not included.

(5) There is no requirement for information on the value of underlying assets held by section 110 companies to be included on the Corporation Tax returns submitted to Revenue. While such information is included on the individual company's annual statutory accounts which must be submitted to Revenue, it is not possible to aggregate this information at an industry level. Accordingly, I am unable to provide this information.

(6) Currently there are 14 staff assigned to Revenue's Financial Services (Banking) District in the Large Cases Division. 6 of the staff are at Principal/Assistant Principal level, 3 at Higher Executive Officer/Executive Officer level and 5 at Clerical Officer level. The majority of the staff in the District are involved to some degree in monitoring section 110 companies. Assistance is provided to the District by other specialised areas of the Large Cases Division, In addition, other specialised areas of Revenue provide assistance in monitoring section 110 companies, including in the areas of legislative interpretation, tax return processing and collection functions. Activities are recorded by reference to function (e.g. audit, other risk interventions, customer service) rather than by reference to taxpayer type (e.g. section 110 companies). It is not possible to estimate the percentage of staff time devoted to dealing with section 110 companies.

(7) Section 88 of the Central Bank Act 2013 allows for the provision of information by Revenue to the Central Bank relating to companies set up in accordance with section 110 of the Taxes Consolidation Act 1997. Two meetings took place with the Central Bank in 2015. The primary purpose of the meetings was to discuss the type of information available to Revenue and agree the format for the transmission of information to meet the requirements of section 88.