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Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: The section 110 companies are probably the best example that have appeared in the past ten years. Is it appropriate that legislation that was intended for usage in financial services was applied to property?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: To get it established.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Circumvent.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: My next question is to Mr. Redmond. Are any of the vulture funds part of the American chamber?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: In terms of the 150,000 staff directly employed, in addition to the approximately 100,000 attached to those jobs, would the US companies stay or, to use the expression, would the horses be scared away from the prospect of Apple having to pay the €13 billion? I am talking in the general rather than about the Apple case.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Unlike my colleague, we will give Mr. Redmond the opportunity to answer that one.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Can I challenge that?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: We do not have a certain environment.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Is Mr. Redmond's organisation concerned about the retrospective nature attached to the Apple case?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: I think they only go back ten years.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Yes. I am sorry.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: I assume Mr. Redmond's body represents many of those marquee names - Apple, Google, etc. What is the primary reason they are established in this country? Is it access to the Single Market or our staff? What is the primary reason they are here?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Not access to the Single Market.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Can I push on Mr. Redmond analysis somewhat as he is in a good position to give a view? In terms of Brexit, we hear of Frexit and the potential prospect of other countries leaving. Could Ireland leave the European Union, the Single Market and the Customs Union and not suffer a huge loss in terms of those type of jobs?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Is Dr. Stewart aware of the Ernst & Young analysis on the CCTB?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: It stated clearly that there would be an enormous transfer. The countries that would gain are the large countries and those that would lose are the small countries. Why would we go down that route?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: It is good to hear Dr. Stewart's view on what would happen. Many get much more air time than he does. On the repatriation of profits to the US from those stateless companies, I recall Mr. Tim Cook clearly stating in an interview that there is a fund of billions of dollars for when Apple repatriates its profits. Should it be the country where the product is invented, created and formed...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: I will ask, because it is something that is important, whether Dr. Stewart saw the committee's view on the CCCTB.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: Were we wrong to take the position we took?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Investigations into Tax Rulings (resumed) (7 Feb 2017)

Michael D'Arcy: In some areas, not all.

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