Results 25,161-25,180 of 27,019 for speaker:Michael Noonan

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Do I have a right of reply?

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The man made many allegations.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: They were not true.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I am sure I can, if the Chair allows me to be out of order.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I thank colleagues for their contributions. As many colleagues have said, loss relief is a standard feature of corporation tax regimes worldwide. Under the Irish corporate tax regime, losses incurred in the course of a business are allowed to be taken into account in calculating the appropriate tax due by companies. Loss relief recognises the fact that business cycles run over a longer...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: As colleagues have remarked, the speaking note I read was extensive and contained a lot of information. I can get my Department to amplify on it and give Members a full written explanation of the points made. I do not want to give a commitment to commission too many reports because my Department would do nothing but produce reports for the next six months if I was to accede to every...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The Deputy is familiar with the DIRT tax regime and also with what we intend to do on foot of the Finance Bill. It is not a policy decision; it is one that stems from a lack of resources to extend it fully. What the Minister of State, Deputy Eoghan Murphy, committed to on Committee Stage was referring the issue to the tax strategy group in mid-summer to get its advice on how we should...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I move amendment No. 35:In page 40, between lines 24 and 25, to insert the following:“other than a loan or a specified agreement which derives its value or the greater part of its value from a CLO transaction, a CMBS/RMBS transaction, a loan origination business or a sub-participation transaction,”. Proposals for an amendment to section 110 of the Taxes Consolidation Act 1997...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: It is very hard to say anything credible in two minutes. If I take Deputy Richard Boyd Barrett's question-----

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Deputy Richard Boyd Barrett asked why we had this provision in place. Some 38,000 people are employed in the financial services industry in Ireland. It is a sector that is expanding and we think it will expand rapidly in the short to medium term because of the relocation of activity from the City of London as a consequence of Brexit. Section 110 of the Taxes Consolidation Act 1997 is...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: If gaps emerge in the course of 2017, I will come back to close them because I know what the policy intent is. It is as I stated to Deputy Richard Boyd Barrett.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Yes. It states the figure is €20 billion.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I will deal with the question on charities. In certain financial transactions it is common practice for the shares in a special purpose vehicle, SPV, to be owned by a charitable trust. In Ireland the only type of purpose trust is a charitable trust. This ensures, first, that the SPV is not consolidated into the accounts of the originator, thereby ensuring the originator is in a position to...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Yes. The charity issue was exaggerated in the coverage of the section 110 issue. It is an accident of Irish law that they are the only trusts available but it was as described in the speaking note. As I stated, this is extremely complicated and we will provide the Deputy with answers to her questions.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I move amendment No. 36:In page 40, to delete lines 34 and 35 and substitute the following:"(c) a loan origination business, (d) a sub-participation transaction, or (e) activities which are preparatory to the transactions or business mentioned in paragraphs (a) to (d),".

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I move amendment No. 37:In page 41, to delete line 1 and substitute the following:"distribution payable thereon; 'sub-participation transaction' means a transaction which involves the acquisition of an economic interest in a loan by the qualifying company in the ordinary course of a bona fide syndication of such loan to one or more lenders where the originator of the loan— (a) is a...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The tax code taxes persons on the profits which they earn. Profits are calculated after taking account of deductions incurred wholly and exclusively in the course of the business from which the profits arise. The Irish tax code does not generally disallow a transaction between connected persons where that transaction is carried out on the same terms as a transaction with an unconnected...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Loans by connected persons to other connected persons will be allowed in general. We would not make an exception in this case provided everything is kosher in the arrangements between them.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Yes. An internal loan is allowed as long as the rate is the same as a commercial third party loan.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The effect of the proposed amendments would be to require Revenue to publish the country-by-country reports filed under section 891H of the Tax Consolidation Act 1997. Section 23 of the Bill simply makes minor amendments to country-by-country reporting as introduced last year. These minor amendments are to ensure our legislation is fully consistent with the EU directive agreed after we had...