Results 11,001-11,020 of 26,610 for speaker:David Cullinane

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

David Cullinane: Why?

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

David Cullinane: I will add something that I should have asked. Dr. Keegan stated that there may not be a tax advantage to incorporate. If a large portion of what in normal circumstances would be considered a salary is treated as profit from a company and is subject to corporation tax, can whatever is left in the company be invested in, for example, property or something else? It would not be drawn down as...

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

David Cullinane: I had plans to get to Waterford by 7 p.m.

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

David Cullinane: I thank our guests and apologise for not being here earlier, as I was speaking in the Dáil. In the earlier exchanges, Mr. Cody referred to tax avoidance. He explained the difference between tax avoidance and tax evasion. There are phrases littered throughout the report to the committee from the Chartered Accountants Ireland representative, as well as in statements made by others....

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

David Cullinane: There is obviously a distinction in law between tax evasion and tax avoidance. Tax avoidance is often seen as something similar to tax efficiency. One maximises advantage through the tax code. One might use it to one's own advantage in a way that was not intended, but it is not illegal. Is Mr. Cody saying that there are instances where the Revenue Commissioners looks at patterns or...

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

David Cullinane: I wish to discuss an issue I raised previously. I raise it again this morning because I struggle to understand how it works, and why the system is the way it is. I refer to very high earners who set up companies rather than receive a salary. In other words, what would constitute a salary is paid to the company and then corporation tax is paid on most of this income and a salary is drawn...

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

David Cullinane: I wish to comment on enhanced pension rules. This morning, I gave the example of a lot of the very senior broadcasters in RTÉ. It has been reported on several occasions that many of them set up these companies. They are on six-figure salaries and they pay corporation tax rather than income tax on a lot of the money they earn. We were told this morning that this is not being done to...

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

David Cullinane: The relevant issues then, are pension contributions, PRSI classifications and possibly allowances write-downs that would not be available to PAYE workers. There is a range of issues.

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

David Cullinane: I do not want to be unfair to anybody, and I note that it is not illegal. By and large, however, I would imagine that, from an individual's perspective, the motivation would be a reduction in tax liability. Would that be a fair assessment?

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

David Cullinane: I saw that.

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

David Cullinane: Okay. I thank Mr. Cody for that. I have a very quick question on Apple, which I know Mr. Cody has dealt with. He has said that Revenue is 99% of the way there in terms of calculating the liability. I imagine that, even though it is only two companies, Revenue will be going back over time. What is the time period it is looking back into?

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

David Cullinane: That would involve any payment which could be perceived as state aid to either of the Apple companies involved. What types of payments would they be in broad terms?

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

David Cullinane: I am not looking for the figures. I am asking whether it is to do with how their taxes were calculated or to do with write-downs, incentives and so on.

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

David Cullinane: Forgive me if I am wrong, but was the judgment not that there was a special arrangement for Apple in terms of state aid rules which did not apply to other companies? Was that not the substance of the Directorate General's judgment? Perhaps the Department might have an answer to that question.

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

David Cullinane: It is not that tricky because the judgment was very clear. The judgment was that favourable treatment was given to Apple. Was that not the essence of the Commission's judgment?

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

David Cullinane: It was made in terms of state aid.

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

David Cullinane: And the Department is appealing that judgment.

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

David Cullinane: I am just trying to understand the calculations. If all state aid which was given to those two Apple companies is being calculated, I would imagine that similar state aid was given to other companies, was it not? I am trying to establish what exactly the Department is looking at to arrive at whatever figure it will arrive at. I am sure it will be greater than €13 billion. Is it...

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

David Cullinane: Perhaps I can put if differently to help the witnesses understand me. I put this question to Mr. Cody. The judgment is that the State did not collect enough tax from Apple. That judgment was because of what the Commission saw as favourable state aid rules being applied to Apple, a special arrangement or whatever way one chooses to phrase it. That was the substance of its judgment, which...

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

David Cullinane: I understand that.