In the 2016 Finance Act I introduced provisions to address concerns raised in both the media and the Dáil regarding the use of section 110 companies and certain Irish collective investment vehicles by international investors to minimise their tax payments on Irish property transactions.
In relation to Section 110 companies the amendments made in Finance Act 2016 will ensure that tax will be payable on their profits from Irish property transactions from 6 September 2016 onwards.
I also introduced the Irish Real Estate Fund (IREF) legislation to address the issue of non-resident investors, who have been investing in Irish property through fund structures, avoiding a charge to Irish tax on profits arising from Irish real estate.
The measures were designed in a very targeted manner to ensure that the Irish tax base will be protected where Irish property transactions are taking place within collective investment vehicles and Section 110 companies whilst not affecting Ireland's wider funds and securitisation industries.
In relation to the two measures, a yield of €50 million was included in Budget 2017. This estimate was both conservative and prudent. To forecast the yield from these amendments into the future requires predicting changes in property prices as well as behavioural changes; as such it is still too early for the Department or Revenue to estimate any potential yield beyond 2017, however based on receipts received to date it is likely that the expected yield in 2017 will be exceeded.
I am advised by Revenue that it is not possible to identify separately any element of the combined yield from the two measures in the tax yield to date in 2017.