23. (1) The Taxes Consolidation Act 1997 is amended:

(a) in section 172A(1) (a), in subparagraph (i) (inserted by section 9 of the Investment of the National Pensions Reserve Fund and Miscellaneous Provisions Act 2009 and as amended by section 240 of the Act of 2009) of the definition of “relevant distribution”, by inserting before clause (IV) the following:

“(IIIA) the Strategic Banking Corporation of Ireland or a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary,”,

(b) by inserting after section 230AB (inserted by section 43(1)(b) of the Finance Act 2003) the following:

“ 230AC. Notwithstanding any provision of the Corporation Tax Acts, profits arising to the Strategic Banking Corporation of Ireland or a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary shall be exempt from corporation tax.”,

(c) in section 246(3), after paragraph (d), by inserting the following:

“(da) interest paid to the Strategic Banking Corporation of Ireland or a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary,

(db) interest paid by the Strategic Banking Corporation of Ireland or a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary,”,

(d) in section 256(1), in paragraph (a) of the definition of “relevant deposit”, by inserting after subparagraph (iiie) (inserted by section 240 of the Act of 2009) the following:

“(iiif) the Strategic Banking Corporation of Ireland or a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary,”,

and

(e) in Schedule 15, in Part 1, by inserting after paragraph 43 (inserted by section 240 of the Act of 2009) the following:

“44. The Strategic Banking Corporation of Ireland or a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary.”

(2) The Stamp Duties Consolidation Act 1999 is amended by inserting after section 108A (inserted by section 139 of the Finance Act 2003) the following:

“ 108AA. (1) Stamp duty shall not be chargeable under or by reference to any heading in Schedule 1 on an instrument for the sale, transfer, lease or other disposition of any property, asset or documentation to the Strategic Banking Corporation of Ireland or to a subsidiary wholly owned by it or a subsidiary wholly owned by any such subsidiary.

(2) For the purposes of subsection (1), whether a subsidiary is wholly owned shall be construed in accordance with section 9(1)(d) of the Taxes Consolidation Act 1997. ”.

(3) The amendments effected by this section do not apply in circumstances where the Minister does not hold all of the shares in the SBCI.