Ms Kate Levey:

I think the Deputy is referring to a Revenue publication and I have another one here before me about corporation tax receipts. It is important to know that corporation tax receipts in Ireland are 8.3% of total tax revenue, equivalent to 2.5% of gross domestic product, GDP. Both of those are within half a percentage point of the average for Organisation for Economic Co-operation and Development, OECD, countries. We collect the same proportion of corporation tax when compared with total tax revenue and GDP as do other jurisdictions.

In respect of the CCCTB, formulary apportionment and how it operates, there are two competing philosophies about how to allocate profits between different countries. On the one hand, there is the OECD and the "arm's length principle", which seeks to identify where value add is generated. It is often generated by relatively low numbers of people where, for example, it is focused on research and development or high value-add types of activity. On the other hand, there is the formulary apportionment, which is divided by staff assets and sales. The difference between consolidation and the current international OECD rules for allocating profits between jurisdictions is that under consolidation, the biggest markets, the jurisdictions where the most sales are made, will capture a proportionally higher amount of the revenue regardless of where the value-added activity took place.