I propose to take Questions Nos. 189 to 191, inclusive, together.
I am advised by Revenue that, with regard to the information included on tax returns filed with Revenue, it is not possible to identify the value of property and real estate investments held by all funds domiciled in the State.
The Deputy will be aware that an IREF is an investment undertaking, or a sub-fund, which derives 25% or more of its market value from assets deriving their value directly or indirectly from real estate in the State. The Irish Real Estate Funds (IREF) regime was introduced in Finance Act 2016 in response to concerns raised regarding the use of certain collective investment vehicles to invest in Irish property. Investors had been using the structures to minimise their exposure to Irish tax on Irish property transactions. The regime provides, with some exceptions, that where a unit holder receives value from the IREF, an IREF withholding tax of 20% will generally apply.
In respect of the value of assets held by Irish Real Estate Funds (IREFs), only partial information is available from the IREF tax returns filed with Revenue for the years 2017 and 2018. In this regard, IREFs are required to file an IREF tax return only where they have a taxable event in a particular year and therefore not all IREFs will have made returns for these years. The initial information in relation to IREFs that have made a return is available at https://www.revenue.ie/en/corporate/documents/research/ct-analysis-2019.pdf.
IREFs were required by regulation to file annual financial statements on or before 30 January 2019 with Revenue for accounting periods which ended during 2017 and accounting periods which ended on or before 30 June 2018. The information contained on the financial statements is currently being reviewed and analysed by Revenue. Once this analysis is completed, Revenue will be in a position to provide more detail on the value of Irish real estate held by IREFs.
In relation to the Deputy's question different types of funds, authorised investment funds in Ireland are established as either Undertakings for Collective Investment in Transferable Securities (UCITS) or Alternative Investment Funds (AIFs). The IREF regime does not apply to UCITS funds as UCITS are widely-held retail funds with diversification requirements. AIFs are authorised by the Central Bank as either a Qualifying Investor AIF (QIAIF) or a Retail Investor AIF (RIAIF). IREFs are generally structured as unit trusts, Irish collective asset-management vehicles (ICAVs) or as a designated investment company. I am advised by Revenue that, as previously stated, as the analysis of IREF financial statements has not yet completed, Revenue is not currently in a position to provide the information requested by the Deputy. I expect this analysis to conclude, and to be in a position to provide the resulting data to Deputies, in the near future.