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Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Right, so it is now €33,000.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: That is the legislation. Maybe it is not Mr. Cody's remit, but where I am sitting, as Chairman of the Committee of Public Accounts, and Mr. Cody has a different perspective, a person can owe the taxman, through income tax or whatever else, such as company or corporation tax, a figure of €50,000 or whatever, and that is published. We are seeing a situation where, from the taxpayer's...

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Do the tax exemptions-----

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Yes, the declaration.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Mr. Cody mentioned the issue of taxation. Ultimately, from the taxpayer point of view, some of a tax credit is money that has been repaid. Have there been many cases where Revenue had paid out the money, paid out the cheque to those people, by way of payable credit and, as in those 178 cases, money had to come back?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Fine, but in these that we are looking at here, which are Mr. Cody's input, had the payments gone out in many cases?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: That could happen, though.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: On tax credits other than for research and development, it is the same situation. If someone has put in quite a big claim and has got the benefit of it, the scale of it does not matter. The legislation will not allow the publication-----

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Explain this now. Does Mr. Cody mean some of these could, in some situations under this thing, be published?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: One can claim it back. What I found interesting about the chart on page 142, which feeds directly into what Mr. Cody is saying, is that when one goes back to 2009 or 2010, when the repayments system really started to kick in, practically all this was by way of corporation tax forgone and there was very little in payments. When I look at the figure for 2014, the only year for which we have...

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: On the cash rebate scheme, it used to be a tax forgone scheme but the balance has now moved to a grant in respect of expenditure. It is a grant scheme now.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: There is a different question. I want the officials from the Department of Public Expenditure and Reform to listen to this and take it back to the Department of Finance as well. Up to 2008, this scheme was exclusively a tax forgone scheme. I can fully understand why it was administered by Revenue. However, now the scheme is a grant scheme for expenditure, the vast majority of the payments...

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: The most recent figures relate to 2015. Do the Revenue Commissioners have estimates for 2016? What is the international comparison of research and development schemes for companies? How much of it is by way of tax forgone as opposed to grants?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Is that 60:40 split now-----

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: I ask Mr. Cody to get that this evening in order that we can see how that compares internationally.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: My next question relates to the first paragraph in the Comptroller and Auditor General's report which reads:The R&D tax credit can be claimed in addition to the standard 12.5% corporation tax deduction [because the scheme is worth 25%]. Therefore, the total tax benefit is 37.5%. Is that correct?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: As Mr. Cody said, the emphasis is on the bigger foreign multinational companies. In 2013, the Department of Finance reviewed the important role it is playing. The scheme is also viewed as a very important element of Ireland’s corporation tax regime in terms of attracting foreign direct investment to Ireland. In light of Brexit and homegrown industries needing to increase their tax...

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: That is a bigger debate. We will not go there today. Essentially, does a company need to be paying tax at 12.5% to get the value of the corporation tax forgone?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: Not assessable at that rate, but do they need to be-----

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Seán Fleming: I think we are nearly there and I might ask the Comptroller and Auditor General to qualify. Everyone who is getting it at the 12.5% rate is paying some element of tax. If a company's credit is more than its tax liability, it might not only have no tax to pay but might also get a payable credit on top of that.

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