Oireachtas Joint and Select Committees

Wednesday, 16 May 2018

Committee on Budgetary Oversight

Corporation Tax Regime: Discussion

2:00 pm

Mr. Seamus Coffey:

I think the point on rates as a source of revenue is well made. This is something into which we are beginning to get insight. The Central Statistics Office has broken down the top 50 foreign-owned companies in its accounts. We get the impact on the amount of corporation tax they are paying. One of the tables includes a heading covering other taxes and production paid. This includes commercial rates, motor tax, the training and employment levy etc. In 2016, a total of €850 million was generated from the top 50 companies. The CSO accounts indicate these companies are paying €2.5 billion in corporation tax. The former figure is a sizable amount. It may only be a quarter of the corporation tax receipts, but it is close to €1 billion. These are significant receipts, especially for local authority rates. I am unsure about commercial water charges but commercial rates are certainly included in the figure. It is not only a matter of corporation tax.

The Revenue Commissioners have examined the other receipts we generate. They have said that when we look at the total of income tax, PRSI and USC, some €7.3 billion arises from multinationals in Ireland. We have vast corporation tax receipts and a significant portion of our income tax arises from them. The figure is close to a quarter of the overall receipts across those three headings.

We do not have a quarter of the employment based in multinational companies but because of the higher levels of pay in them, the proportion of income tax, university social charge, USC, and pay related social insurance, PRSI, arising from them is quite large. We are getting some insight on that from the figures provided by the various agencies and the concentration in commercial rates and other payments, which may be worth noting.

On the issue of the sustainability of corporation tax and why one would argue that it might not be sustainable, one of the reasons is that we do not know why it happened. Nobody predicted in 2015 that corporation tax receipts would jump by 66% in one year. If there is such a large jump in such tax receipts in one year, the fear is that it could reverse quite quickly. Quite a wide variety of factors led to that. I do not believe all those factors are going to unwind in any given year. There was a timing issue involved but some of those factors could unwind. We face unknown developments in the future that could cause receipts to change, whether it be US tax reform, which appears to have worked in our favour up to now, changes at OECD level, which again appear to have worked in our favour up to now, and changes at EU level, the most significant of which it now appears are not going to happen. However, we cannot expect international changes will always work in our favour, but they have up to now.

On the sectors, we collect significant revenues from the information and communications technology, ICT, sector and I would say the broader manufacturing sector, rather than just including the pharmaceutical sector. That includes computer chips, medical devices and the manufacturing of soft drink concentrate across a wide range of areas. The financial sector is one that should get attention when considering corporation tax receipts. It is our second most important sector for receipts of corporation tax, which may be surprising when Irish banks pay and will continue to pay very low levels of corporation tax for a wide variety of reasons. I imagine much of that tax in the financial sector arises in the International Financial Services Centre, IFSC, and foreign owned companies. It would be worth considering the financial sector as one that might need greater scrutiny. There was €1.8 billion of receipts in the financial sector in 2017. The companies and the types of activities in which those are based could be footloose, therefore, it would be worth considering what is going on there.

Regarding Irish companies, the Revenue Commissioners do not tell us the breakdown of the companies ranked in the top ten. Therefore, we do not know the big payers in the top ten companies. When it comes to the top 100 payers, the Revenue Commissioners have indicated there are some Irish companies among them. They indicated a figure of fewer than ten. They have not given us a precise number. Of the top 100 payers, there are some Irish companies among them. Fifty-one of those companies are US based. They far outweigh the Irish presence. The overall amount of tax paid is quite low. The top 100 companies paid €5.9 billion in 2017 and the fewer than ten Irish companies included among the top 100 paid €370 million. The payments of some individual companies would exceed that figure. Most of the receipts come from foreign companies.