Richard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance) | Oireachtas source

One of the things to which Seamus Coffey also alludes, which the Minister and everyone else knows, is that the value ascribed to these intangible assets, and the key is in the word "intangible", as in "we do not know", is ascribed by the company itself. That is what happens. The company gives these assets precisely the value that is necessary to ensure that it pays no tax. That is the way it works and Seamus Coffey says it very clearly. The increase in capital allowances almost exactly offsets the increase in intangible asset-related profits such that the onshoring of these assets resulted in little or no additional corporation tax being collected in 2015. That is the way it has always worked, including with the double Irish. He also pointed out that the Minister's decision to not apply the new reduced cap on the allowance for intangible assets was unprecedented in terms of the treatment of such assets because whenever changes were made previously, they applied to all claims. He points out that the specific regime for capital allowances for intangible assets was introduced in 2009. Amendments were introduced in the Finance Acts from 2010 to 2014. He goes through a number of the changes and points out that all previous changes to the regime applied to all claims for capital allowances related to expenditure on intangible assets and were applied to all claims for capital allowances under the regime. The most recent change is the first occasion on which a change was introduced to the regime that only applies to new claims. Who does that suit? It suits Apple and a few other companies. In fact, the full extent of the lost tax revenue is apparent in the Revenue tables on tax expenditures which jump by about €9 billion or €10 billion between 2014 and 2015.

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