Mr. Seamus Coffey:

It is an issue where we can look back and see the evidence of it, but forecasting Irish corporation tax receipts is very difficult. We have seen these sorts of level shifts. There were maybe two of them from 2015, and again in 2021-22, when those receipts surged. We can look back and see them but they were very difficult to forecast at the time. It is also because it is so concentrated. The top ten companies account for close to 60% of the receipts. Work by staff in the fiscal council shows that the top three account for more than a third. We are down to very firm-specific factors. On whether the forecasts are conservative, they have clearly been outperformed by the out-turns over recent years. It could be said there are some measures that have not been taken into account. When we look at it over the medium term, we see some elements that could cause Irish corporation tax receipts to rise further, maybe beyond what the projections have set up, but there could be other factors we do not see that cause them to fall.

Some of these companies may drop in profitability. We referenced intellectual property that came to Ireland six or seven years ago. The capital allowances linked with many of those assets are set to run out. That might expose more of the profits to our corporate tax rate. We have the minimum tax where liabilities are accruing from 2024, which is not yet fully built into the forecasts. Again, the policy environment of other US companies being subject to this is all up in the air. We just highlighted that the receipts are huge.