Cian O'Callaghan (Dublin Bay North, Social Democrats)

I touched on the issue of corporation tax, IP and related assets with the Minister earlier. Dr. Aidan Regan in UCD has done detailed work in this area and is a leading expert on this. The Minister said previously that these are operations of substance involving research and development, that people are employed and that there are services and manufacturing. Dr. Aidan Regan has done much detailed research on this area and has given a contrary view. He said what mostly resides in Ireland is not the intellectual property itself, but the right to monetise it and financial instruments designed to reroute global profits with minimal local activity. He goes on to say that windfall corporation tax receipts rest on fragile accounting arrangements, and that a multinational can therefore hold the underlying IP in the US while assigning the right to monetise it elsewhere to an Irish subsidiary, with the US parent retaining control of research and development while the Irish entity books international income, claims the profits and pays little tax. He says that these arrangements run counter to the spirit of international tax reform. He says that what is in Ireland is not substance but legal scaffolding. I would be interested in hearing the Minister's response to that because Dr. Regan has done detailed work in this area.