Michael Noonan (Limerick City, Fine Gael)
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There is a very high level of compliance with corporation tax. A small number of companies pay large amounts of tax. The current controversy is very unfair to the tax situation in Ireland. Every company in Ireland which is liable to pay 12.5% on the profits they earn in Ireland is paying it. It is a very tax compliant country. Many of the profits made by multinational companies are not subject to Irish taxation, and if that is the case we cannot collect money from the parts of their profitability which are somebody else's responsibility. That is from where the extraordinary figures arise.

Apple is being talked about. It paid 12.5% on all the profits it made in Ireland, and that is the only liability it has in Ireland. It might pay less elsewhere. Companies registered in the Deputy's constituency are not obliged to pay tax in Ireland because they are not registered for tax in Ireland.

Today's Financial Times refers to a figure of $1.2 trillion overseas dollars from the United States which is not repatriated because the United States makes a distinction between profits generated domestically and profits generated abroad. We are not in a position to remediate that. Today the Wall Street Journal states:

The Apple units are registered in Ireland so US law does not consider them to be US corporations subject to US corporate tax. But since they are managed and controlled by Apple in the US, Irish law does not consider them to be Irish companies and thus they are also not subject to the 12.5% Irish corporate tax. This isn't alchemy, it's accountancy.

It supports the Irish position. The Financial Times stated:

But the senators would do better to look closer to home. An over complicated US tax code has allowed the principle of no double taxation to degenerate into one of double no taxation ... But to be fair, there is no evidence that Ireland struck preferential deals with Apple ... Much of the avoidance cited is routinely used by US multinationals thanks to a tax code which invites this through differing treatment of foreign and domestic earnings. At the last count US companies held $1.7 trillion in remission profits. Rather than bash companies in foreign countries, the Apple example should encourage Congress to move on corporate tax reform.

Any of us who have jobs in our constituencies in companies like Apple, which employs about 4,000 people in Cork, should remember about 100,000 people are employed in US multinationals in Ireland. We would want to be very careful that we do not join in this clack of criticism when the Irish taxation system is totally transparent.

The rate of 12.5% applies to all profits from multinational companies in Ireland. There are no arrangements made between Revenue and multinationals operating in Ireland. Irish tax is not a matter of administrative arrangement, as are tax systems in some other European countries. Irish tax is governed by law passed here and in the Seanad. The Revenue Commissioners must abide by that law and must apply the law fairly and evenly, and does so.