Ruth Coppinger (Dublin West, Anti-Austerity Alliance)
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278. To ask the Minister for Finance the amount that could be raised from imposing a 2% public health levy on the profits of private human health and pharmaceutical companies here, including nursing homes and home care agencies. [25358/16]

Michael Noonan (Limerick City, Fine Gael)
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I am advised by the Revenue Commissioners that on the basis of information included in the Corporation Tax returns filed for the tax year 2014, the potential yield from imposing a 2% levy on the profits of private human health and pharmaceutical companies, including nursing homes and home care agencies, is tentatively estimated to be in the region of €150 million, with over 99% from the pharmaceutical companies.

 This yield is based on the industry code assigned to companies on Revenue records and does not include any yield associated with subsidiaries of these companies not primarily involved in the sectors mentioned in the question.  It has been assumed that the levy would apply to the taxable profits of pharmaceutical companies, nursing homes and home care agencies but would not apply to medical practices or private hospitals. Additionally the potential yield assumes no significant behavioural change on the part of these companies that could cause the expected levy yield to fall below expectations and could also cause a decrease in Corporation Tax receipts.

Pearse Doherty (Donegal, Sinn Fein)
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279. To ask the Minister for Finance the number of Irish tax opinions that have been given regarding property investments held through Irish regulated funds structure including AIFs and ICAVs and also for those relating to section 110 companies for each of the years 2010 to 2015, in tabular form, given that typically an Irish tax opinion would be obtained to provide tax certainty for the investor; and if he will make a statement on the matter. [25400/16]

Michael Noonan (Limerick City, Fine Gael)
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I am informed by the Revenue Commissioners that section 110 TCA 1997 contains a list of the assets which a qualifying company is allowed to hold/manage.  Property is not one of those assets.  

For the purposes of section 110 TCA 1997, a qualifying asset is a financial asset, commodities or plant and machinery.  Financial asset includes (but is not limited to) shares, bonds and other securities, derivatives, receivables, leases and hire purchase contracts, bills of exchange and similar negotiable instruments, carbon offsets and contracts for insurance.  "Commodities" means tangible assetsother than currency or financial assetswhich are dealt with on a recognised commodity exchange.

Revenue issued two opinions in 2012 in relation to property investments and section 110 companies.

Revenue have no record of any opinions sought during this time regarding property investments held through Irish regulated funds structures.