This amendment was not announced in Budget 2017 but provides for a new taxing method for fund structures where at least 25% of the value of the fund is made up of Irish real estate (IREF). The amended legislation states that IREFs must deduct 20 per cent withholding tax on certain property distributions from the fund.

It is envisaged that such distributions, made out of profits from Irish land, are payments made to non-resident investors who potentially could fall outside the charge to Irish tax. Certain categories of investors such as pension funds, life assurance companies and other collective investment undertakings are exempt. Additional text to the legislation was included at Committee Stage.