Pearse Doherty (Donegal, Sinn Fein)
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68. To ask the Minister for Finance the net total dividend withholding tax paid by IREF funds in respect of dividends paid to non-resident investors and other relevant parties in 2016 and 2017 in tabular form. [40141/17]

Paschal Donohoe (Dublin Central, Fine Gael)
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The Irish Real Estate Fund regime, which was introduced by section 23 Finance Act 2016, took effect from 1 January 2017. Therefore, there were no distributions by IREFs in 2016.

IREFs must operate a 20% IREF withholding tax on the happening of certain taxable events (such as a distribution of profits or a redemption of units). IREF withholding tax is a separate tax to dividend withholding tax and the normal exemptions which apply to dividend withholding tax do not apply to IREF withholding tax. If a non-resident who owns less than 10% of the units in an IREF is resident in a country with which we have a double tax agreement, then, depending on the terms of the agreement, they may be entitled to claim a refund of some or all of the IREF withholding tax deducted. Non-resident investors who hold more than 10% of the units in an IREF are not entitled to claim a refund of IREF withholding tax under a double tax agreement.

Any withholding tax deducted in respect of distributions made during 2017 must be returned to Revenue by the end of July 2018. Therefore, I am advised by Revenue that they are not yet in a position to identify the amount of withholding tax relating to IREF taxable events that have happened so far in 2017.