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Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: What was the tax debit or, if one likes, the other half? There was a loss of income to Ireland as a result of that agreement. Were there gains for Ireland as a result of the double taxation agreements?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: I know.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Okay. From a layman's point of view, Mr. Cody has just said the tax credit cost Ireland €900 million, or just short of €1 billion.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: If that was the loss to Ireland as a result of the agreements, which countries were the beneficiaries of the €900 million? Does Mr. Cody understand my question? It is a simple one. If we lost, who gained?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: I understand that.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Has there ever been a stage at which a double taxation agreement resulted in a net flow into Ireland? I can understand what Mr. Cody is saying about now.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: From the point of view of a person watching this, Mr. Cody has just said that this double taxation arrangement has resulted in €900 million less tax being paid in Ireland because it was paid in other countries. Has there ever been a reverse in that situation where Ireland was up €900 million? Is it because our tax rate is lower than other countries'?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: We would have been a beneficiary.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: The US has a higher rate.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Has Mr. Cody any idea of the geography? He is saying that, where some countries have a lower rate than our 12.5%, the cost might generally be borne by them in these arrangements. I am saying this on behalf of the people watching us. They see a cost to the Exchequer of €900 million. Mr. Cody will say that it is difficult to know where it went, given that different countries and...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Mr. Cody might send us a note.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Yes.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: With what Revenue can.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Fine. We have discussed multinationals all day without mentioning any specific one. How many are traditional Irish multinationals? I am referring to large Irish companies that also operate abroad. Has this conversation been dealing with foreign multinationals as opposed to domestic, home-grown, large multinationals that operate worldwide? We know that some Irish companies have a large...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Of the top 100 companies that the witnesses have been referring to and whose identity we do not know, how many are foreign multinationals versus large Irish companies?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Some of the Irish multinationals, for example, Kerry Group, Glanbia and so on, are big by international standards. They are multinationals.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: They do not feature in our top-----

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: I am only mentioning them for the purpose of having an example. Very few-----

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Mr. Cody can understand this simple question. When we discuss multinationals, we always seem to think of foreign direct investment, FDI. Irish is now a net investor abroad.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Some day, we should have an equivalent discussion about Irish companies. As Mr. Cody mentioned, most of the companies in the top 100 are foreign direct investors into Ireland. We have a chapter on corporation tax. I do not see the other half of the chapter, which should deal with the large Irish multinationals that are presumably resident in Ireland. At least, I hope they are resident...

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