Pearse Doherty (Donegal, Sinn Fein)

No problem at all.

Let me move abroad with the next question. Questions have been asked about tariffs, but there is also the matter of the implementation of the BEPS process. Could the Minister outline the undertaxed profits provision rule, which relates to any jurisdiction that does not apply a minimum effective tax rate of 15%? We know some jurisdictions may calculate it in a different way if outside the BEPS process. Where we have a subsidiary of a relevant company in this State, we have to tax the entity here in Ireland. I am asking this having regard to the US. The measure came into effect on 1 January, or the fiscal year after 31 December last year, so it now has been in play for several months. This issue has been raised in the discussions on the US tariffs. Since the US has, unfortunately, withdrawn from the agreement – I hope it will come back under it – could this State, in light of legislation that has passed through the Houses, have to levy tax from an American company because it has a subsidiary here?

I have asked this numerous times, but we are getting closer and closer to the Finance Bill. I made the point, when dealing with a previous Finance Bill, that it was never envisaged that a global entity such as the US would not be part of the deal. There was always a threat under pillar 1 but pillar 2 is now an issue. Does the Minister envisage a need to revisit this as a result of decisions that have been made, particularly by the US?