Ms Laurena Leacy:

I will take the Deputy's first question, which was on the losses. Under Article 15 of the regulation, the contribution applies to taxable profits under national tax rules. If Ireland were to implement the contribution in accordance with the corporation tax rules as they are now, due to the nature and history of the sector, we would collect little if any contribution due to the amount of losses carried forward from previous years. Recital 55 of the regulation provides that member states are to implement fully the contribution and may account for the treatment of losses in previous years. In 2022, the Government decided that the losses from previous years would not be included. This has the effect that companies cannot offset their losses from previous years against the contribution, resulting in a lower collection by the State. Under the general scheme, losses from before 2018 cannot be carried forward into the period and losses cannot be carried back from 2023. Losses within the period from 2018 to 2023 can be brought forward, as the Deputy has said. The reason that losses predating that period are not included is that we are attempting to maximise the return and windfall gain to the State. I hope that answers the Deputy's question.