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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)

Richard Boyd Barrett: If I could interrupt Mr. O'Brien, I get his point-----

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)

Richard Boyd Barrett: That interesting justification does not explain how the chief executive officers and the major shareholders in these companies are astronomically rich compared with the cleaning lady who is cleaning their toilets.

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)

Richard Boyd Barrett: I could point out that the average worker, having paid their 25% in tax, then pays double tax in the form of parking charges, water charges, property tax, VAT and so 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)

Richard Boyd Barrett: I refer to the issue of effective tax rates and Mr. O'Brien's claim that they are higher than some are claiming. We can see some of the figures, and they were alluded to by Mr. O'Brien in his introduction. I got this table about a year and a half ago and tried to draw some points out of it publicly because I was quite shocked by what I consider to be the effective rate, which is the amount...

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)

Richard Boyd Barrett: No. It is a gross profit figure.

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)

Richard Boyd Barrett: Forget about Revenue for a minute. I am talking about EUROSTAT. Clearly, EUROSTAT is taking gross profit and the actual amount of tax paid as a proportion of gross profit and working out the effective rate, what it calls the implicit rate, from that. Is that not what it is doing?

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)

Richard Boyd Barrett: Is it not more to do with the amount that is written off taxable profit in the form of what are called trade charges? Just €14 billion of the €73 billion pre-tax profits are royalty payments paid by a multinational to the exact same multinational. That multinational decides how much it will charge itself for the right to use patents and intellectual property rights because...

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)

Richard Boyd Barrett: I put it to-----

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)

Richard Boyd Barrett: I hope I get the time back.

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)

Richard Boyd Barrett: I want to drill down into that but in the short time available we will not have enough time to do that in the detail in which it should be done. When a multinational is selling stuff to itself, is it not the case that it can charge what it likes in reality? It is very convenient if it charges a very high price for that because it writes down the amount of profits that are then liable for tax.

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)

Richard Boyd Barrett: But it does not sell this stuff to third parties because the whole point with regard to the companies with which we are dealing-----

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)

Richard Boyd Barrett: ----- and precisely what characterises them is they keep their stuff to themselves. They keep their intellectual property, patents, software systems or whatever it is to themselves and sell the product precisely on the basis that one buys it uniquely from them and can get it from nobody else.

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)

Richard Boyd Barrett: To use a phrase, it strikes me that there are lies, damned lies and multinational accountancy practices and that there is enormous scope for abuse with regard to how the company quantifies the cost and value of these patents. It strikes me that this is one of the key mechanisms that allows such companies to write down their taxable profits and that this area must be examined a hell of a lot...

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)

Richard Boyd Barrett: My last question is about incorporation versus management control, which is another mechanism through which another whole raft of profits - not even included in these figures - are simply not discussed or included at all. Are the management and control criteria for tax residency completely archaic and out of date in the modern globalised economy? Where does one define this in a...

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)

Richard Boyd Barrett: Does Mr. Taft wish to comment?

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)

Richard Boyd Barrett: May I ask one further 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)

Richard Boyd Barrett: On the alternative position put by Mr. Taft, he has suggested that were we to adjust the tax position, on its own it could have an impact on the levels of investment. How does he tally that with his other argument, which is that as a result of Ireland's low tax rate, we have a low level of corporate investment when compared with our European neighbours? I do not quite discern how these two...

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)

Richard Boyd Barrett: The Chairman gave Deputy Dara Murphy a second round. Can I have a second?

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)

Richard Boyd Barrett: It is not a Second Stage speech and the Chairman allowed Deputy Dara Murphy three extra questions. I just want one.

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)

Richard Boyd Barrett: Given what Mr. Taft stated about higher effective rates elsewhere not being detrimental to the levels of corporate investment, is there any evidence to suggest that if, for example, we applied a minimum effective rate to gross profits of, say, 12.5% or increased the nominal rate to approximately 15%, which would still leave our effective and nominal rates significantly lower than everywhere...

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