Results 4,281-4,300 of 45,510 for speaker:Simon Harris

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 50:In page 47, line 8, to delete “relevant company” and substitute “relevant company, which has made a claim under this section,”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 51:In page 47, lines 36 and 37, to delete “profits, calculated as if this Chapter did not apply,” and substitute “profits”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 52:In page 49, lines 25 and 26, to delete “to which this Chapter applies” and substitute “in respect of which a claim was made under section 769I(2)”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 53:In page 51, to delete lines 38 to 41, and in page 52, to delete lines 1 to 3.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 54:In page 52, line 4, to delete “(2) Subject to subsection (5)” and substitute “769O. (1) Subject to subsection (4)”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 55:In page 52, line 24, to delete “(3) Subject to subsection (5)” and substitute “(2) Subject to subsection (4)”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 56:In page 52, line 36, to delete “(4) A relevant company” and substitute “(3) A relevant company”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 57:In page 52, line 41, to delete “(5) Where” and substitute “(4) Where”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 58:In page 53, line 5, to delete “subsections (2) and (3)” and substitute “subsections (1) and (2)”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 59In page 54, line 38, to delete “and”.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: I move amendment No. 60:In page 54, to delete lines 39 and 40, and in page 55, to delete line 1 and substitute the following:“(ii) where that company is a member of a group, the group has turnover not in excess of the turnover threshold amount, and (iii) the company is a micro, small or medium-sized enterprise within the meaning of the Annex to Commission Recommendation 2003/361/EC of...

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: We are probably both proud of the fact that we have a very difference perspective on this section of the Finance Bill, in terms of our views on the knowledge development box. It is not fair to say that the Minister was dragged, kicking and screaming anywhere in the context of his approach to ensuring that this country promotes best practice when it comes to taxation and plays a prominent,...

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: The payment dates for preliminary tax, such that it will be €31 million next year but it would be €50 million in a full year. How we are arriving at the figure in terms of the expected cost is an important question. The annual cost of the knowledge development box in terms of tax foregone from 2016 forward have been estimated. This focused on companies who up until this year...

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: No. In 2013, the total corporation tax liability of all six firms was €1.4 billion. That figure relates to the outer limit of tax that could be reduced by the KDB rate.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: On the latter point, the qualifying income is the trading income that is derived from the qualifying assets. This includes royalties that are attributable to the assets and sales income. Any income that results from a disposal of the qualifying assets, such as the patent, will remain subject to the capital gains tax, CGT, rate. Chargeable gains are not subject to the KDB rate. It is the...

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: Yes.

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: When a company sells a product that derives some of its value from intellectual property, IP, but is not in itself IP then it will be able to avail of the KDB in relation to those products. The legislation provides that where any amount of the sales price of a product or service is attributable to one of the qualifying assets, namely, a patent, a copyright, a software or a third category of...

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: On the issue of State aid and the EU, which is an issue previously raised by Deputy Michael McGrath, the KDB complies with the modified nexus standard which was agreed with the OECD as part of the base erosion and profit shifting, BEPS, process. The EU code of conduct has approved and adopted the modified nexus standard. Clearly, the tax sovereignty of a member state is a member state...

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: Are we still on table 3.25?

Committee on Finance, Public Expenditure and Reform: Select Sub-Committee on Finance: Finance Bill 2015: Committee Stage (Resumed) (18 Nov 2015)

Simon Harris: That is way out. The Deputy is speculating. No decision has been made on anything. I enjoy wide-ranging discussions, but it is going a bit far to speculate on the outcome of a European Commission ruling.