Mr. Seamus Coffey:

No. The report indicates it should be considered. We would need sufficiently strong CFC rules in place to ensure companies do not try to benefit by moving profit from Ireland and moving it back in while saying it is not Irish profit. Those rules would have to be introduced first.

If the rules were strong enough, then one could consider moving towards a territorial regime. As it stands with our worldwide regime, if companies shift profits to no-tax jurisdictions and bring them back in, they will not get a foreign tax credit because they have not paid the tax. We, in a sense, protect ourselves from that sort of circular motion.

Regarding the EU, I do not believe the move Ireland might make from a territorial to a worldwide regime will have an impact on digital taxation or the amount of tax which would be collected in EU countries. It depends on where the profits are generated and reported. The EU is suggesting we need different rules on that.