Oireachtas Joint and Select Committees

Wednesday, 11 June 2014

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

Reform of Global System of Corporation Tax: EU Commission and KPMG

3:30 pm

Mr. Liam Lynch:

I am not familiar with the figures to which the Deputy is referring, so I apologise for that. I can add a couple of comments with regard to the transfer pricing practices. Without looking at the individual companies and how the figures build up it is not clear to me what drives some of these figures. Some of it might be driven by issues which are being looked at as part of the BEPS process but in my experience, and I would have been involved in these as well, some of it may also be driven by other countries applying their own transfer pricing rules and saying that a company should be charging its Irish company for the IP that is owned here as well. Quite an amount of this, and I do not know to what extent, may also be even transfers for IP within the EU which is being charged for and which is actually being subjected to quite robust transfer pricing in countries at present. To the extent that the figures relate to that or to some other matter, I cannot tell from the general figures the Deputy has quoted.