Gerry Horkan (Fianna Fail) | Oireachtas source

I think six member states have issued reasoned opinions. What is the Commissioner's response to our reasoned opinion? There are a lot of concerns. While the Commissioner is saying it is a proposal and that we have engaged, co-operated and participated in country-by-country reporting, we have enormous concerns, as Senator Kieran O'Donnell and others outlined, about sales which do not take place in Ireland. There is a sales tax right across Europe called VAT or something similar. Corporation tax is usually based on where production takes place. If production takes place in Ireland, the tax on the profits belongs to Ireland. If production takes place in Germany or Singapore, the profits should be chargeable to tax there. It is now being moved and the weighting of one third, one third and one third is very arbitrary. It also excludes non-fixed assets. Therefore, a lot of the assets of most companies will be discounted in the calculation.

At our hearings in advance of coming to our reasoned opinion we asked academics and tax practitioners if this was a power and a tax-take grab by large countries from small ones and they said it was. I do not doubt that the statistics indicate that the European Union economy as a whole will grow, but in the absence of any analysis - the Commissioner has alluded to the fact that there is none - every member of the committee finds it hard to believe we will do better if all of the tax that used to be paid will move away, if the base is narrowed and the two other rates fall.