Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

The Minister said that the Department of Finance would set out options and that he would make the policy decisions. However, in setting out options, he said that the Department would also convey views. Has the Department given a view or a recommendation on this specific issue? It is important that the Minister would answer that question. How long will it be before the capital allowances in respect of the IP onshored prior to budget day will have been exhausted? That is a particular number of years. How long before that will be exhausted? The Minister did not answer the question about the yield from this. What is the basis of the estimate that this will bring in an additional €150 million in 2018?

I ask the Minister to deal with the issue of the risk that this is not a timing issue and that there is a loss to the Exchequer as a result of this over time. This goes back to the points that Seamus Coffey made when he outlined three key risks in that regard. First, it requires the profits to be present in the future in order for the tax to be collected. Second, some of the intangible assets will, by their very nature, be time limited. Third, there is a risk of the asset leaving the country when the capital allowances have been exhausted. Capital allowances will be exhausted at some point in time so the argument that it is a timing issue is dependent on there still being taxable income in respect of those companies after the capital allowances in respect of the IP onshored up to budget day have been exhausted. That really is the nub of the issue.

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