Mr. Conor O'Brien:

While one certainly could argue that, in one sense one could argue the place of residence is irrelevant. This is because no matter where a company is resident, its pays tax wherever it has a taxable presence, that is, a permanent establishment or a branch and I note the threshold for having a branch is very low. Consequently, even if a company is not resident in Ireland, it pays tax here if it has an office or staff here and so on. It pays tax here and has a taxable presence here. The companies that have attracted attention are companies that are Irish-incorporated but which have no presence here whatsoever. Consequently, wherever they should pay tax, it certainly should not be in Ireland. For me personally, the residence issue is a little bit of a red herring because of what happens if one has a taxable presence - a branch - here in Ireland. The Deputy mentioned a multinational company that might have hubs and offices all over the world but if it has, it will pay tax and have taxable presences in each of those countries.