Speaking in a newspaper interview last month, Revenue Chairman Josephine Feehily was categorical about Revenue using its powers to obtain information from NAMA.

The Chairman was quoted in the Sunday Tribune saying that “We will be getting a list of eligible bank assets transferred to NAMA. It will include details on the asset, the borrower and we will be able to go back to NAMA for details underpinning those transactions, all with a view to adding to our understanding of the structures people used: what they did with the money they borrowed and who borrowed it, as opposed to who appeared to borrow it”.

Section 204 of the National Asset Management Agency Act 2009 gives Revenue significant powers to obtain information from the Agency. They may seek from NAMA “information in the possession of NAMA, or which NAMA has knowledge of, in relation to a named relevant person” and NAMA is obliged to provide it. The definition of “relevant person” is wide, and extends beyond the borrower –

• “relevant person” means a debtor, associated debtor, guarantor, surety or chargor and includes a connected person (within the meaning given by section 10 of the Taxes Consolidation Act 1997) in relation to a debtor, associated debtor, guarantor, surety or charger”

Given the level of detail being demanded by NAMA in business plans by the borrowers, the information which Revenue might obtain could be considerable.