The National Asset Management Agency has made a preliminary tax payment of €158m due on profits made by the agency from sales of property held through controversial Section 110 companies.

The liability arises following the closure of a loophole in the 2016 Finance Bill.

NAMA said as a result of these changes it had made a preliminary payment of €158m to Revenue last November, based on its estimated profit between September and December 2016.

NAMA's quarterly report for the three months to the end of September last year shows it made a profit on asset disposals of €795m between January and September. The agency is expected to report a full year profit of around €1.5 billion indicating it made substantial gains on sales completed during the fourth quarter.

Section 110 vehicles, so called because of the relevant section in the 1997 Taxes Consolidation Act which enabled their creation, have been used by investment funds to minimise taxes due on gains made by selling commercial property bought during the recession.

The provision was amended in the Finance Bill, according to the Minister for Finance Michael Noonan, because of concerns about "possible use of aggressive tax practices by some section 110 companies to avoid paying tax on Irish property transactions".

Research undertaken by UCD's School of Social Policy for RTÉ's recent documentary The Great Irish Sell Off showed 24 Irish subsidiaries of international investment funds, which between them have bought assets here worth €20 billion, paid less than €20,000 in corporation tax over the past two years.