Paschal Donohoe (Dublin Central, Fine Gael) | Oireachtas source

I do not believe that the use of double taxation agreements in the past was a key reason the behaviour that the Deputy refers to happened. This agreement is important with regard to how we will deal with this kind of issue in the future. I draw the Deputy's attention to a number of elements of the agreement that I believe will be important in how we deal with this issue in the future. The preamble is now different to the texts that the Deputy would have seen in the past. It is clear that not only is its purpose to eliminate the risk of double taxation and it is also clear that it does not want to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements. As I mentioned in my opening statement, that preamble was the text that the Revenue Commissioners then used in dealing with some issues that were identified with the use of the so-called and alleged "Single Malt". Article 1 about how hybrids will be treated and Article 22 about the principal purpose test will make an important and positive difference in ensuring that global companies pay a fair level of tax and that this is more transparent.