Oireachtas Joint and Select Committees

Tuesday, 16 November 2021

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach

Finance Bill 2021: Committee Stage

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

I appreciate the explanation, but pardon me if what is happening here is still less than crystal clear. Transfer pricing rules are attempting to deal with some of the things we discussed earlier, such as the tax avoidance strategies we know companies engage in whereby there are multiple companies associated with each other within a particular group. The Minister is saying there are checks and balances, essentially, that this will not be used for tax avoidance and that if the Revenue Commissioners suspect any such thing they will ensure the companies are excluded from the expanded relief. The problem for us in trying to scrutinise this, which it is our responsibility to do, is to understand what sort of transactions we are talking about in slightly more understandable language, to put it bluntly. To what type of businesses does this relate? I know the Minister cannot name businesses, but what type of businesses or transactions does this involve? He referred to non-trading transactions. Can he give us an example of what type of non-trading transaction, if I understand it correctly, between associated companies was being unfairly caught up in the sweep of what are sort of anti-avoidance rules and measures, so that we can understand that what he is doing is not going to open unintended consequences from which companies can benefit or allow them to exploit the relief, if you like, or the extension of the relief? Can the Minister give us an understandable example of that type?

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