Oireachtas Joint and Select Committees
Tuesday, 23 July 2013
Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation
Global Taxation Architecture: Discussion with Director of the OECD Centre for Tax Policy and Administration
1:20 pm
Mr. Pascal Saint-Amans:
On the first question, clearly it is to reconcile the location of the real activity and the location of the profit. It is to make sure that countries get the right to tax and do not face base erosion through artificial settings such as massive interest deductibility, the use of hybrid mismatches from entities or products and other harmful tax practices, but also through artificial shifting of permanent establishments by not meeting the current definition, abuse transfer pricing rules or just use of the transfer pricing rules, which we would then need to change.
As to whether we are confident to implement the action plan, I am paid to make sure we implement this action plan and I am paid to be optimistic and to turn optimism into action. I am confident we will be able to do it because we have political consensus on the action plan. The way we have played it has been to make sure that we would have an agreement on the sense of direction. What has been agreed and what was released a few days ago is an action plan which states: "These are the problems. These are the solutions. This is where we want to be in 18 to 24 months time". There is political consensus at the highest level, including among the G20 countries. It is not all about the G20 countries. We are servicing our member countries - the 34 member countries of which Ireland is one - but we also have the endorsement by the G20 countries, which means that we have reached out of the OECD membership. This has been endorsed and because of the political profile of that project, it has been endorsed by the governments, not only by tax people, and because we have political agreement, I believe it will be easier to turn to the tax people, the technical people, and tell them that they need to develop the instruments but that they know where they must be in two years' time because there is political agreement on the solution. That is why I believe we will implement this plan within the timeframe, which is ambitious, but on the other hand, if we said there was a major problem and we would take ten years to solve it, that is not solving it. That is why we thought we needed to have this ambitious political deadline of 18 to 24 months.
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