Oireachtas Joint and Select Committees

Thursday, 7 October 2021

Public Accounts Committee

2020 Annual Report of the Comptroller and Auditor General - Chapters 15 and 16
2019 Annual Report of the Comptroller and Auditor General - Chapter 16
National Treasury Management Agency - Financial Statements 2020

9:30 am

Ms Susan O'Halloran:

Certainly. What that relates to is US withholding tax. Under the US tax rules, as a general matter, withholding tax is deductible from interest from a US source that is payable to a non-resident. There are various exemptions and situations in which that does not apply. Deputy Devlin will see that the withholding tax that is referred to there was repaid and refunded in full to the fund in 2020. The reason it was deducted in the first place was that our escrow agent custodian, Bank of New York Mellon, has the obligation to make the deduction, so it is its obligation to look after that, and it notified the NTMA and Apple that it had made a mistake in its classification of the escrow fund for US tax purposes. It corrected that and it has confirmed the classification as an escrow settlement fund for US tax purposes, which effectively means that no US withholding tax will be deducted until such time as the escrow fund is released from escrow.