Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

I thank Mr. Saint-Amans for clarifying the point. He has confirmed to the Chairman that the corporation tax rate in each country is a sovereign matter for that country, but when he was in Ireland recently he made a comment that if a country has a 12.5% rate then he would like to see companies actually paying 12.5%. That comment was seen very much in the context of the debate that has been ongoing from the US Senate hearings and the hearings in the House of Commons Public Accounts Committee as well. Is it not the case that Ireland operates a very transparent transfer pricing regime? Is it not also the case that when there is commentary that certain companies in Ireland are only paying a 2% rate it does not take account of the fact that we can only tax companies that are tax resident in this country and only on taxable profits? Is it not also the case that in arriving at a figure such as 2%, which I know Mr. Saint-Amans did not – I do not direct the accusation at him – people are confusing the profits of tax-resident Irish companies with companies which are connected but which are tax-resident elsewhere, and which, while they may be incorporated in Ireland, have no activities, assets, employees or income in Ireland? Could Mr. Saint-Amans clarify his position on that? He was very clear to the Chairman that the 12.5% rate is an Irish decision, and that is not on the table in any respect, but could he clarify what he means in terms of the actual rate that is paid and his comment that companies should pay 12.5% if the rate is 12.5%?