Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

Looking at the figures, the change that lifted the cap from 80% to 100%, made in the Finance Act 2014 which came into effect in 2015, has had a staggering impact. Seamus Coffey's online blog makes for very insightful reading. In 2014, when the 80% cap last applied, €2.6 billion of capital allowances were claimed under that regime. In 2015, when the cap was increased to 100%, €28.9 billion was claimed for capital allowances under that regime. This is a more than tenfold increase in the amount of capital allowances claimed in 2015 over 2014. Presumably, this is directly linked to the change of the cap from 80% to 100%. Figures from the Revenue Commissioners show there was a €26 billion increase in intangible asset related gross trading profits in 2015. There was a dramatic change in the onshoring and the claiming of capital allowances against intangible asset related income. Does the Minister have data on how much intellectual property, IP, was actually onshored since the change came into effect in the Finance Act 2014? We need to tease out what is there with regard to stock, IP and related capital allowances since that period of time. A while ago the Minister said that the corporation tax system should be certain and predictable. Up to 2014 he had the 80% cap then he removed that and it became 100%. Now, less than three years later it is going back to 80%, but all the IP, which was onshored in the intervening period, will continue to benefit from the 100% set-off around the limit on income; they can be offset by the capital allowances and the IP. Will the Minister give the committee the data he has on the IP that was onshored so we can tease out, from a tax point of view, the consequences of treating the capital allowances associated with those?