6. Discretionary portfolio taxation
The income and profits of the Fund are exempt from Irish Corporation Tax in accordance with section 230(1) and 230 (1A) of the Taxes Consolidation Act, 1997 as amended. The Fund may, however, be liable for taxes in overseas jurisdictions where full tax exemptions are not available.
Dividends and interest may be subject to irrecoverable foreign withholding taxes imposed by the country from which the investment income is received. Distributions of income and gains received by the Fund from its property and private equity fund investments may also be subject to foreign withholding taxes. The Fund may also be subject to additional foreign taxes payable on certain property and private equity investments annually, based on their asset values at the reporting date.
The foreign taxes provided for are detailed below:
| 2016 €m |
2015 €m |
|
|---|---|---|
| Withholding tax reclaim | 0 | 2 |
| Foreign taxes on income | 10 | (8) |
| Net tax cost | 10 | (6) |
The Fund received €0.3m (period from 22 December 2014 to 31 December 2015: €1m) withholding tax reclaims in relation to tax reclaims submitted for the year ended 31 December 2016. The Fund received a refund of €13m from the United States in relation to the NPRF during 2016.