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Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Mr. O'Brien is in the international market. Is certainty an asset or would there be a concern if there was a question mark over it?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: There are ethics involved. I was at a chartered accountancy event and ethics in business is an issue.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: To assist the Deputy-----

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: I will give the Deputy the time. In a situation where the intellectual arm of the company is taking intellectual copyright money and another arm of the company funds the development of the construction of that factory in Ireland and puts a base interest rate on the repayment of that loan, which would be well above what would be bought in the market, that comes into the equation. Is that right?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: The Deputy has two minutes left.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Yes, if it is short.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Deputy Dara Murphy, briefly.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Deputy, your question.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: I gave Deputy Boyd Barrett a couple of minutes overtime. If it will be short rather than a Second Stage speech, I will let him in.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: It takes Deputy Boyd Barrett the same length of time to ask one question. He should ask a question.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Question made. Mr. O'Brien, then Mr. Taft and then we will wrap it up.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Question and answer, please.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: I will move on to the round-up, if Deputy Boyd Barrett keeps interrupting.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Time is what I allocate. One can use one's time to ask three questions or ask one, but Deputy Boyd Barrett's questions go on and on.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Deputy Boyd Barrett should do himself a favour and ask short questions.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: That one is fine. I want to go on to Mr. Taft. Let Mr. O'Brien answer the question. Then we will ask Mr. Taft. If Deputy Boyd Barrett interrupts once more, I will bring the question to an end.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: You do not.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: To clear up a couple of matters, Deputy McGrath asked Mr. Taft to provide additional information. Maybe Mr. O'Brien could provide the committee with a similar calculation of effective tax rates from other European countries where that is working out. It would assist us.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: We would be very grateful for that. I ask Mr. O'Brien and Mr. Taft to make their own final conclusions. On a final matter, on the transfer pricing arrangements, should we be charging some sort of percentage rate of tax or withholding tax on these transfers?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Ireland's Corporate Tax System: (Resumed) KPMG and Unite (28 May 2014)

Ciarán Lynch: Have analytical figures been run on what the incomes might be?

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