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

Catherine Connolly: It is not a repayment.

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?

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

Catherine Connolly: Are these all different companies or are the same companies picked on?

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

Catherine Connolly: Does Revenue avail of external expertise in respect of this analysis?

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

Catherine Connolly: What is the cost of that? How is it managed?

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

Catherine Connolly: Revenue seeks out the appropriate expertise to advise it.

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

Catherine Connolly: Is there a figure for the cost of that every year?

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

Catherine Connolly: Relatively small, that is, compared with the yield that it gets.

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

Catherine Connolly: Mr. Cody said section 110 was being used in a way never envisaged. Has Revenue identified other issues emerging now?

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

Catherine Connolly: Is there a specific team doing that?

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

Catherine Connolly: Many politicians have raised section 110 in the Dáil. The last time Mr. Cody was before us he told us, and he is saying it again, that the Revenue proactively identified the difficulties with that and flagged it to Government.

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

Catherine Connolly: At the time, proactively-----

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

Catherine Connolly: Are there other issues that it is flagging proactively or has done over the past year or two?

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

Catherine Connolly: In due course this year will Revenue flag issues?

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

Catherine Connolly: Mr. Cody talks about risk analysis and so on. Some Deputies did a great job in the Dáil explaining section 110 to us. I was not up to speed on it at the time. Mr. Cody says Revenue was proactively looking at that. Is it proactively looking at other issues now?

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

Catherine Connolly: Is there one on any issue Mr. Cody can identify?

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

Catherine Connolly: It is. That is right.

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

Catherine Connolly: If Revenue was so proactive on the section 110 companies, and I accept that it was, why did it take such an effort and so much debate in the Dáil specifically on that section to change it? Is there a mechanism for changing such that when Revenue identifies problems, it goes forward and action is taken?

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

Catherine Connolly: I know that. I am talking about Revenue's role in proactively coming forward.

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

Catherine Connolly: I understand that. I want to raise two more issues, residency in 183 days and Apple. I will bite into that apple. I do not expect Mr. Cody to comment because of the court case but I want to run something by him about the acknowledgement. The two companies in question that operated in Ireland, Apple Sales International, ASI, and Apple Operations Europe, AOE, were taxed for the purposes of...

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