Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

I will be very quick on the rest of this. There is a nuance in our existing law. When this agreement is signed and ratified with the Netherlands and Switzerland and with the others, including Luxembourg, later this year, will it then consider the permanent establishment of existing companies or will it just apply to new establishments that are changes in residence applied after that date?

Among the changes we made in the Finance Act 2018, we introduced measures which would tax assets that were transferred from a permanent establishment, PE, to another subsidiary of the company, from the parent company, or one part of it, to the other, if they were moved offshore. Do any of these arrangements impact on that?

I am teasing out some of these issues because of the case that is mentioned in the newspapers. Is there anything in these double taxation agreements that allows or disallows companies to carry on this type of practice where assets are signed over to another country and then loans are sent back to Ireland to build apartment blocks or whatever?

Therefore, these companies in Ireland pay no tax on profits whatever. The Revenue Commissioners are silent on this and there are no questions about measures to combat tax avoidance.

I got a call from a local shopkeeper who employs many people in a certain village. The Revenue Commissioners were down on the shop like a tonne of bricks because it was facilitating the sale of mass cards for the local church. The shop was not benefitting at all but the Revenue Commissioners argued this could have increased throughput into the shop as somebody might come in for a mass card but get a loaf of bread at the same time. The arrangements I am talking about are not about paying €5 to show sympathy and respect for somebody who has passed away but the hundreds of millions of euro in convoluted schemes that allow assets to be transferred offshore, with loans generated on the back of those assets to allow for profits to be completely neutralised in tax terms here. It means some of the largest businesses on this island are not paying their fair share of tax, if they are paying any tax at all. Will those practices still be allowed under this agreement and the agreement to be signed in November this year?