I propose to take Questions Nos. 148 and 150 together.
Section 23 of the 2016 Finance Act introduced the Irish Real Estate Fund legislation(IREF) to address concerns regarding the use of funds in Irish property based transactions.
The IREF legislation was the subject of lengthy discussions at both Committee and Report stages of Finance Bill 2016, during which it was emphasised that the IREF legislation will trigger behavioural changes which cannot be predicted.
This position still stands and therefore data in respect of potential revenue related to ending the exemption from IREF withholding tax for non resident IREF shareholders, from dividends related to the sale of property held within an IREF for five years, is not available.
Furthermore, to estimate the yield from this amendment into the future requires predicting changes in property prices. That, coupled with the behavioural changes, mean it would be premature for the Department or Revenue to predict the expected revenue from introducing a minimum rate of 25% IREF withholding tax at this point.