Oireachtas Joint and Select Committees

Wednesday, 18 September 2013

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation

Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue

3:25 pm

Mr. Eamonn O'Dea:

I am not immediately familiar with the specific figures to which Deputy Doherty refers. Taking 2010, for example, there would have been charges deducted in computing profits a significant proportion of which could have been royalties but not near the figure that he mentions.

The main point is that where royalties are paid to companies that are resident abroad, typically, it is for assets that were developed outside the country. They could have been developed on the US west coast, in Silicon Valley or wherever. They have been funded abroad, they have been patented abroad and they are licensed abroad. They do not have a connection with the country other than there is licensing in for production and manufacture here, for services that are rendered from Ireland or whatever, and they have to be remunerated. In many of the high-profile cases, they are fairly unique world-leading intangibles and, unsurprisingly, they get a remuneration that is proportionate to their status and value.