Stephen Donnelly (Wicklow, Independent) | Oireachtas source

I have no idea. I think that is important because it follows on to the next question. I would like to see and would love to know whether Professor Barry has seen an analysis of the quantums involved. As far as I can tell, there are four different types of tax paid and avoided in this country. I would like to hear Professor Barry's thoughts as to whether these four segments are correct. The first is corporation tax paid here in full, be it at 11.1% or 12.5%. I deem the research and development credits to be perfectly legitimate.

Segment 2 is an interesting one and consists of taxes paid here in full plus more. This is something we know the UK is beginning to look at. An example would be an advert sold in the UK to a UK company with the advertising in the UK but where there has been an exchange on a server sitting in Dublin and, therefore, the profits for that are declared here at 12.5% rather than in the UK at 40%. In this second segment, we gain from companies paying on revenues from here and abroad.

The third segment is transfer pricing. Let us go back to GIZMO where the holding company may be resident here and the operating company pays €500 million in royalties and then declares €500 million in taxes. Corporation tax is paid here but not fully and the royalty transfer would not be included in the effective corporation tax.

The fourth segment is taxes not paid anywhere. Apple has discovered this loophole between Irish and US law. I have the briefing note to the US Senate sub-committee which said that Apple Operations International, which has no employees or physical presence, is managed and controlled in the US and received $30 billion of income between 2009 and 2012, has paid no corporate income tax to any national government for the past five years. In Professor Barry's opinion, are these the right four segments: normal tax paid; normal tax paid plus a bit, possibly from activity in the UK; part tax paid due to transfer pricing; and no tax paid due to non-residency anywhere or residency for the holding company in a jurisdiction where there is zero corporate tax paid?