Written answers

Wednesday, 16 May 2018

Photo of Richard Boyd BarrettRichard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance)
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26. To ask the Minister for Finance the number of SPVs registered here in each of the past three years; the amount of tax paid by these companies; the amount of tax foregone due to particular tax breaks for SPVs; and if he will make a statement on the matter. [21489/18]

Photo of Paschal DonohoePaschal Donohoe (Dublin Central, Fine Gael)
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It is assumed that by SPVs the Deputy is referring to companies who have submitted notifications to Revenue that there are qualifying companies for the purposes of section 110 of the Taxes Consolidation Act 1997 (TCA) (known as “section 110” companies).  Section 110 sets out a regime for the taxation of special purpose companies set up to securitise assets. 

Securitisation is the process by which finance is raised in capital markets based on the intrinsic credit strength of assets or other sources of cash flow, independent of the creditworthiness of the original owner of the assets.  Securitisation is an integral part of the global financial services industry.  Its importance has been recognised by the European Commission through their work on Capital Markets Union, of which one of the aims is to seek to build a sustainable securitisation regime across the European Union.

I am informed by Revenue that the number of notifications received by Revenue from companies that are “qualifying companies” for the purposes of section 110 of the TCA since 1 January 2015 is as follows:

YearNumber of Notifications Received
2015423
2016477
2017759
Year to 30 April 2018171
Total1,830

The amount of tax paid by section 110 companies in each of the years 2015 to 2017 is as follows:

201520162017
€m€m€m
Corporation Tax65199128
Value Added Tax 16.411.214.8
Payroll taxes 1.43.42.3

It is not possible to calculate the amount of tax that would have been payable by such companies had the section 110 regime not existed as the information necessary to determine this is not required to be returned to Revenue.

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