Oireachtas Joint and Select Committees

Thursday, 2 December 2021

Public Accounts Committee

2020 Report of the Comptroller and Auditor General and Appropriation Accounts
Vote 9 - Revenue Commissioners
Chapter 12 - Controls over the Temporary Wage Subsidy Scheme
Chapter 13 - Revenue's Management of Suspicious Transactions Reports

9:30 am

Photo of Brian StanleyBrian Stanley (Laois-Offaly, Sinn Fein)
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I will ask about Perrigo's tax settlement in respect of the 2013 period. The original figure was €1.636 billion which, according to details in the correspondence, was the assessment set out by Revenue at the time. It related to intellectual property. As I understand it, there was a court judgment and the judge agreed with Revenue on the figure and the classification. The court judgment looked at the debate regarding whether this figure was part of normal trading practices or a capital exchange, which was how Revenue treated it, that would have brought in a 33% tax rate. Perrigo argued that this figure was part of its normal day-to-day business and it wanted it treated at the normal corporation tax rate of 12.5%. I do not want to be unfair to Mr. Cody, but is it the case that it was subsequently treated at the normal corporation tax rate of 12.5%? Or was it 33%?