Pearse Doherty (Donegal South West, Sinn Fein) | Oireachtas source

Without going into the details of any company, the Minister is well aware that the "double Irish" practice exists. Companies set up secondary Irish companies, register in tax havens, base their intellectual rights there and pay a dividend from the Irish resident company to the tax haven resident company. It is not that they are paying less than 12.5%, but the companies' overall profits are being siphoned off to secondary companies that do not pay tax. They do not do this to avoid paying tax in Ireland, but to avoid paying tax in America, as the interaction between the two companies are not taxed when the profits are repatriated. The Minister, President Obama and the American Administration are well aware of this and we need to be careful so that profitable companies cannot avail of tax loopholes of which the Department is well aware and to which it has turned a blind eye. What contact has the Minister had with the American Administration? Prior to the last presidential election, there was discussion of clamping down on this practice. Changing the American tax code would make attracting American multinationals to Ireland difficult. The Minister needs to tread carefully. While it may be the case that companies are paying tax of 12.5% on the profits registered in Ireland, the Irish tax code allows the "double Irish" practice to exist.

See this speech in context