Michael McGrath (Cork South Central, Fianna Fail)
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162. To ask the Minister for Finance further to Parliamentary Question No. 193 of 7 February 2017, if he will provide details of the use of section 110 companies by the Irish Bank Resolution Corporation, IBRC, including the number of section 110 companies set up by IBRC; the purpose of setting up these companies; when they were set up; if third parties were involved in these companies; the tax implications of using this tax structure; and if he will make a statement on the matter. [7406/17]

Michael Noonan (Limerick City, Fine Gael)
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I am advised by the Special Liquidators of IBRC that there were no active Section 110 structures in place at the time of their appointment. However, they have identified at least two historic loan securitisation transactions that involved the use of Irish Section 110 structures which were unwound prior to their appointment. The information available to the Special Liquidators indicates that the transactions involved the securitisation of loans (including non-Irish loans) to raise cost efficient funding for the then bank's day to day business. Such securitisation transactions are commonly undertaken by banks around the world to raise funding. The information available to the Special Liquidators would indicate that the transactions identified were typical of the securitisation transactions generally undertaken by banks and were not of the character targeted by the changes to the Section 110 regime introduced by Finance Act 2016.