Oireachtas Joint and Select Committees
Tuesday, 17 September 2013
Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation
Base Erosion and Profit Sharing: Discussion with Trinity College
3:35 pm
Professor Frank Barry:
One can split that pie any way one wants. One could look at it from the viewpoint of the British tax authorities, the Irish tax authorities and global tax authorities. One could chop it up any way one wanted. Let me make one point about this. As an US company, if Apple's profits accumulating from wherever, presumably somewhere in the Caribbean because it tends to be the Caribbean, are ultimately distributed to Apple shareholders, they must go back to the US.
That triggers a tax liability. If they are not repatriated to the US, which they must be if they are to be distributed as dividends, they contribute to the value of the company, in that they are invested overseas and the value of Apple shares increases. As a capital gains liability will be triggered on that, there will be some tax revenues. While this is not optimal by any means, the profits will be reflected in the company's share price, regardless of where they are accumulated. I imagine that the Deputy knows more about this matter than I do. The profits either go to shareholders in the form of distributed profits or they are reflected in share prices, thereby triggering capital gains tax. They do not disappear into the ether. This is finance, whereas my area-----
No comments