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Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: That is what I wanted to discuss. I have read the up-to-date brief. What I gathered from Dr. Keegan's document last week was that criteria existed, the situation depended on whether one was a company or an individual and on whether there were double taxation agreements with specific countries, etc.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: The criteria are clear. Dr. Keegan was at pains to say that, in the case of close companies, trying to use that system to try to avoid paying tax would be punitive.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: I read this document last night, but then I considered Apple. According to page 37, the head office was not tax resident in any country. I do not want to get into the specifics, as I understand the matter is before the courts, but I will ask in a general way as a result of what Dr. Keegan stated. There was a head company, with two companies operating in Ireland - Apple Sales International...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: From 2014?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: So prior to that, in addition to Apple, any company could have been or was doing this for all we know. Companies could have done exactly what Apple did, namely, not have been resident in any country for the purposes of tax but could have had two branches in Ireland that were only caught for limited amounts here while the vast profits went to a company that was not tax resident anywhere. Our...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: Dr. Keegan is very good.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: I appreciate that and I do not expect Dr. Keegan to comment. Am I wrong if I say that there could have been 1,000 companies or 100 companies doing that?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: What did it have to do with?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: It could not be looser.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: I welcome Mr. Cody back. I wish it was the multinationals we had before us but Revenue is the second best in this regard. The context was set during this morning's session and in the Comptroller and Auditor General's chapter, which Revenue knows well, regarding the variation in the collection of corporation tax, with the effective rate ranging from 12.5% to 0%. I am sure Mr. Cody watched...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: Using that credit legitimately, a number of major companies do not pay corporation tax. How many do not pay tax?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: We know there is variation and we have been led to believe that headlines that say the companies pay nothing are unfair because there are many legitimate reasons they do not. Is that correct?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: For every €4 spent on research and development, €1 comes back. How does Revenue monitor that? Does it audit randomly?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: I will just stick to 2016. What was the yield?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: No, that is okay. What percentage of the overall number of companies does 270 interventions yielding €13 million represent?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: Let us discuss 2015. A total of 1,532 companies availed of the research and development credit. Did Revenue examine all of them?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: What was the yield in 2015 as a result of Revenue's interventions?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: Mr. Cody gave us the 2016 figures.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: So slightly fewer companies yielding but more money and fewer interventions. Why were there fewer interventions?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed)
(22 Feb 2018)

Catherine Connolly: Is that yield a repayment?

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