Richard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance) | Oireachtas source

I had better move on because my time will run out. One of the things the Paradise Papers reveal is that in the case of Apple, following the moves to close down the double Irish at the end of 2013, the intangible assets allowance was increased to 100%. Then it moved some of its subsidiaries based here to Jersey or the Isle of Man. I cannot remember which but it was one of those tax havens. It had advice to the effect that this would allow it to avoid tax as the Jersey entity would sell the assets to the Irish-based company which could claim that as a cost against which it would get an allowance and would pay no tax. That was perfectly fitted. Apple engineered it in such a way that its tax liability was exactly the same as it had been when it was using the double Irish structure. It could set the price at whatever it wanted such that its tax liability did not change. That is clearly tax avoidance and Apple is clearly manipulating the price at which one subsidiary is selling an intellectual asset to another subsidiary to ensure it pays no tax. Is there anything we can do about that? It is very obviously a manipulation of the tax code.