Mr. Conor O'Brien:

I think they could, and I will explain the reason. Something to bear in mind is that a corporation does not actually exist. Under corporate law 101, a corporation is a legal fiction. When the Deputy says the corporation is paying a 12.5% rate of tax, it is not as if there is a corporation in an armchair in a mansion on top of a hill rubbing its hands with glee because it has a low tax rate. Corporations do not exist. They are a vehicle for collective investment and pooling of funds by shareholders. All taxes are ultimately borne by individuals. Corporation tax is a double tax on investors in shares. For example, if somebody has a pension fund and that pension fund invests in, say, a United States multinational company, that US multinational invests in Ireland and pays 12.5% tax in Ireland. When those profits are repatriated to the US, a further 22.5% of tax will be paid. Meanwhile, the pension fund is paying in Ireland 0.75% of the capital value of the fund under the pension levy. That is on the capital, not on the income. In some years there might be no income because the company might make losses. Risk-free returns are 2% or 3%, which are the current interest rates, and 0.75% is perhaps 20% or 25% of the risk-free return, the risk-adjusted return.