Pearse Doherty (Donegal, Sinn Fein)
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251. To ask the Minister for Finance the total number of section 110 applications, that is, unique form S.110 submissions each year since 2016; the total number approved; the number approved in each type of transaction classes; the number approved for dealing with each qualifying asset type, in tabular form; and if he will make a statement on the matter. [13158/25]

Pearse Doherty (Donegal, Sinn Fein)
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264. To ask the Minister for Finance the number of section 110 special purpose vehicles in operation each year from 2016 to 2024 and to date in 2025; and if he will make a statement on the matter. [13208/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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I propose to take Questions Nos. 251 and 264 together.

Section 110 of the Taxes Consolidation Act 1997 sets out a regime for the taxation of special purpose companies set up to securitise assets. The tax provisions are intended to create a tax neutral regime for bona-fide securitisation and structured finance purposes. The section 110 regime enables noteholders to invest through one structured vehicle, without giving rise to an additional layer of tax as compared to a direct investment in the underlying assets.

Securitisation allows banks to raise capital and to share risk and, by providing a repackaging and resale market for corporate debt, it lowers the cost of debt financing. It is accepted that having the option for more diversified sources of financing is good for investment and business. It is also important for financial stability in the economy, as the ability to securitise loan books plays an important role in allowing banks to meet their capital requirement obligations and to continue lending to businesses and individuals.

To come within the section 110 regime, a company must be a “qualifying company” and fulfil a number of conditions, including in relation to the type of assets that the company can hold and in turn the nature of activities that may be undertaken by the company. To be a qualifying company, section 110 TCA 1997 requires (among other things) that:

1. The company is tax resident in Ireland and carries on the business of holding or managing "qualifying assets". Generally speaking, qualifying assets are assets in respect of which securitisation transactions are undertaken. This includes a broad range of financial and other assets including shares, bonds, derivatives, loans, deposits, commodities, plant and machinery and invoices and other types of receivable.
2. The value of qualifying assets is at least €10 million at the time they were acquired by the section 110 company.
3. Apart from the holding or managing of the qualifying assets, the company is not carrying on any other activities.

• it is, or intends to be, a 'qualifying company'
  
  and
• it meets the criteria of paragraphs (a) to (e) of the definition of 'qualifying company' Section 110(1) of the TCA, 1997.

Pearse Doherty (Donegal, Sinn Fein)
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252. To ask the Minister for Finance to provide an exhaustive list of the State’s double taxation treaties; and if he will make a statement on the matter. [13159/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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Tax treaties allow for the smooth and regulated taxation of international business and investment activities. Ireland’s longstanding tax treaty policy has been to expand, maintain, and enhance its network to remove barriers and facilitate trade and investment opportunities between Ireland and partner jurisdictions. They provide greater certainty and fairness for taxpayers regarding their tax obligations in foreign jurisdictions and are key to the prevention of double taxation. Furthermore, they provide for dispute resolution mechanisms and exchange of taxpayer information to enhance tax transparency.

In June 2022, the Department of Finance published Ireland’s tax treaty policy statement. The published policy statement sets out the broad parameters of Ireland’s policy based on two central themes – consideration for Ireland’s economy and trade and recognition that different considerations apply to tax treaties with developing countries. The statement identifies key priority areas for the coming years to ensure the continued expansion and enhancement of our tax treaty network.

Ireland’s tax treaty network is extensive; Ireland has signed 78 tax treaties, of which 75 are currently in effect. Ireland has tax treaties with all EU Member States and all OECD member countries, bar the two newest members (Colombia and Costa Rica ).

The table at the following link sets out the full list of treaties as requested:

">Tax Treaty Table