Mr. Barry Andrews:

The recovery and resilience fund, RRF, allocation is just under €1 billion, as Deputy Haughey said. One of the critical ways in which the agreement was arrived at in July last, when the frugal four governments were anxious about the lack of contingency associated with the allocation of the RRF, was that there would be these measures put in place. We are used to the country-specific recommendations that come out annually from the Commission and require each of the member states to develop social policy, economic policy and fiscal policy in line with the overall direction of travel in the EU - let me put it that way. I am not surprised that there is a reference here to aggressive tax planning. The big issue here is the initiative of President Biden and what that means for the Irish corporate tax rate. We have been clear all along that we are open to whatever comes out of an OECD process so that there will be a global tax regime that allows for reasonable tax competition. That has been Ireland's position consistently. If the OECD goes down the road of finding a solution that is acceptable to the US and to the EU and to others in the OECD, then it would be very difficult for Ireland to resist that. That is the reality of the situation.

There are two big meetings coming up. The G20 is meeting in July and October. It is more likely that an agreement will emerge in October. As I understand it, the US Treasury officials are just reading themselves slightly into their brief under the Biden Administration and July is a little soon. Certainly, by October, we will see the shape of a potential agreement. This is all happening very quickly. The proposals in the Biden Administration, for its own corporate tax rate but also for the global intangible low-taxed income, GILTI, tax rate around intellectual property, are very significant for Ireland if adopted but the landing ground is probably going to be somewhere a little less than what is proposed. Instead of 21%, the GILTI rate might be in the late teens. It is a watching brief. Ireland has always been nimble in arguing its point. As long as we retain tax autonomy, we will be able to safeguard our industrial model.

I would agree with the view that if this proposal had come along 20 years ago, we might not have been able to cope with it. I agree with the view of Mr. Seamus Coffey that it probably will not impact on investment currently in Ireland but it could have an impact on investment in the future, that is, the foreign direct investment, FDI, pipeline that has been positive.

On the Brexit adjustment reserve, BAR, this has been a big green jersey effort. All of the MEPs tried to make an impact and tried to safeguard Ireland's interest in the BAR. It was an outworking of the July 2020 European Council. The outcome is slightly less than we had initially hoped for but it is still a positive one. It is between 20% and 21% of the overall total or €1.06 billion out of €5 billion, but it is not settled yet. There are still discussions going on at European Parliament level. There will be a vote next week in the budget committee. I am continuing to engage with the French rapporteur on that file - Deputy Harkin will be aware that is a tricky enough discussion to have - but we are not alone. There are other smaller member states impacted by this, namely, Belgium, the Netherlands, Denmark and Sweden, that have shown a common way of thinking about this with Ireland. Whatever the outcome, it is quite positive for Ireland. It is a little less than we had initially hoped for but that is the European method.