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Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: The report was critical of the level of expertise within the Revenue Commissioners.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: I asked him a direct question. Mr. Cody heard that.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: I asked Mr. Coffey a direct question.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: I did not hear that.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: That is the Revenue Commissioners.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: That is just for pricing.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: What does Mr. Cody define as the competent authority?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: Is Mr. Cody saying the competent authority is a strategic unit as distinct from an operational, practical unit in terms of audit?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: Was it at one stage?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: What about prior to that?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: If a large multinational company came into Ireland and, as all companies do, came up with a transfer pricing model within its group company structure, how would that fit into Revenue in terms of-----

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: What happened back then?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: Pre-2010 and post-2010 are very different.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: If there is a large multinational company engaged in transfer pricing over many years and it is using a certain model under self-assessment, was the type of transfer pricing model it was using reassessed by Revenue post-2010? Are they still operating on a self-assessment basis?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: Does risk-based involve potential loss of revenue to the Exchequer? Would that feed into it?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: Based on the discussions between the competent authority-----

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: That is based on discussions that would have taken place between the competent authority in Ireland and other companies units in Europe and so on. My understanding is that a defined agreement with other countries is agreed upon------

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: Is that based on company-specific cases?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: The competent authority does not deal with general issues but, rather, company-specific matters.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Paradise Papers: Chairman, Office of the Revenue Commissioners (29 Nov 2017)

Kieran O'Donnell: I see where Mr. Cody is coming from. What is his view of Seamus Coffey's statement that the competent authority element is not sufficiently resourced, although it has sufficient expertise?

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