Oireachtas Joint and Select Committees

Thursday, 5 November 2020

Public Accounts Committee

2019 Annual Report of the Comptroller and Auditor General and Appropriation Accounts
Vote 7 - Office of Minister for Finance
Chapter 1 - Exchequer Financial Outturn for 2019
Chapter 17 - Ireland Apple Escrow Fund

11:30 am

Mr. Derek Moran:

The third-country adjustments are just the ordinary operation of international tax. For example, at any given time the Irish competent authority, which would be the Revenue Commissioners, could be in discussion with the competent authority in the United States of America or in Italy or Spain about companies that have a presence in multiple jurisdictions, and if a portion of that tax should be paid here, and vice versa. These adjustments are reasonably routine. Do not forget that this Apple money goes back over a period of ten years so the adjustments were made. Third-country adjustment has very little, if anything, to do with the case itself. It is that tax moneys are owing to the country. These are routine transactions that go on. They probably could diminish over time given the fact that this is historical.

They are just properly payable and the Commission, when it reached its adjudication, recognised that there would be some draw on these funds and that adjustment could be made of the top without us in any way invalidating its obligation to collect the money.

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