Mairéad Farrell (Galway West, Sinn Fein)
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These changes seek to provide greater clarity around our transfer pricing rules and the circumstances in which domestic non-trading transactions between Irish entities are excluded from the application of the rules. It is good to make the rules clearer. However, I would be concerned if it would allow for the possibility of transfer pricing arrangements via special purpose vehicles, SPVs, and financial vehicle corporations, which appear to take place at arm's length because they use the orphan ownership-type structure we discussed yesterday. In reality, these are essential intragroup transactions designed for the purpose of tax minimisation. If a company uses an orphan structure with legal trustees holding the issued share capital, will Revenue and the Central Bank look to find the ultimate beneficial owner when trying to ascertain whether transfer pricing arrangements are being used?