Cormac Devlin (Dún Laoghaire, Fianna Fail)
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305. To ask the Minister for Finance if he will expedite targeted modernisations to the Section 110 regime, including rectifying unintended impacts of recent credit rule changes, modifying the day €10 million asset threshold, extending the eight-week election period, and consolidating duplicative interest deductibility provisions; the public consultation plan; the expected timeline for draft legislation; the anticipated impact on private credit and infrastructure finance activity in Ireland; and if he will make a statement on the matter. [48078/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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Section 110 of the Taxes Consolidation Act 1997 provides for the taxation of certain Special Purpose Entities (SPEs) and was introduced to support securitisation. It was designed as a tax neutral regime for securitisation transactions.

My predecessor Minister Chambers published the Report of the Funds Sector Review 2030 on the 22 October 2024. This report fulfilled the recommendation from the Commission on Taxation and Welfare for, among other things, an examination of the use and scope of the section 110 regime and made recommendations to address potential risks arising in respect of the section 110 regime through enhanced transparency. Officials in my Department are reviewing these recommendations along with consideration of developments at an EU level on securitisation, related policy discussions on simplified interest deductibility under the Public Consultation on the Taxation of Interest and other issues raised by industry representatives. I, in turn, will consider these matters in due course.