Dáil Éireann Debate, Tuesday - 24 July 2018
354. Deputy Richard Boyd Barrett asked the Minister for Finance the amount of tax revenue foregone as a result of section 110 tax relief as it applies to rental income and capital gains from property for all the years to which the section applies; and if he will make a statement on the matter. [35009/18]
Amharc ar fhreagraI am advised by Revenue that companies which have submitted a notification to Revenue that they are a qualifying company for the purposes of section 110 of the Taxes Consolidation Act 1997 (TCA 1997) can only hold certain qualifying assets. Real property is not an asset that a qualifying company can hold, however they can hold loans and other financial assets that derive their value therefrom.
As part of the 2016 Finance Act, provisions were introduced 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. The amendments made in Finance Act 2016 ensure that tax will be payable on their profits from Irish property transactions from 6 September 2016 onwards.
It is not possible to calculate the amount of tax that would be paid if a company had not submitted a notification to Revenue that it is a qualifying company for the purposes of section 110 TCA 1997.
