Oireachtas Joint and Select Committees

Thursday, 2 February 2017

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach

EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners

9:30 am

Mr. Niall Cody:

Yes, that 55% to 60% belonged to ASI, AOE and Ireland. When Mr. Cook represented it as a particular percentage, the Irish tax rate over the non-Americas profits gave the sum. The 12.5% tax rate was applied to the profits attributable to the Irish branch. There was no deal or special arrangement. All of the cases that we are dealing with - 19 were mentioned, but there are effectively 11 and Apple in the decision - involved the calculation of the profits attributable to the relevant Irish branch and the application to those of the statutory corporate tax rate of 12.5%.

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