Results 21,501-21,520 of 27,945 for speaker:Michael McGrath

Joint Oireachtas Committee on Finance, Public Expenditure and Reform: Forthcoming ECOFIN Council: Minister for Finance (18 Jun 2014)

Michael McGrath: Is it the Minister's position at this stage - I appreciate that we are still a number of months away from the budget and that there will be a lot of discussion and analysis - that if there is some headroom, if he can stay within the 3% deficit figure with an adjustment of less than €2 billion, that is his intention?

Written Answers — Department of Finance: Universal Social Charge Yield (18 Jun 2014)

Michael McGrath: 33. To ask the Minister for Finance the yield in each year since the universal social charge was introduced, including the 45% rate of USC that applies to the employees of financial institutions that have received financial support from the State and receive performance related bonus payments, if the provision still applies; and if he will make a statement on the matter. [26167/14]

Written Answers — Department of Finance: State Investments (18 Jun 2014)

Michael McGrath: 39. To ask the Minister for Finance the use to which the proceeds from the sale of Bank of Ireland preference shares were put; and if he will make a statement on the matter. [26286/14]

Written Answers — Department of Finance: National Pensions Reserve Fund Plans (18 Jun 2014)

Michael McGrath: 40. To ask the Minister for Finance if proceeds from the sale of NPRF's discretionary portfolio will be available for investment in a manner similar to the proceeds from the sale of the directed portfolio; and if he will make a statement on the matter. [26287/14]

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: They sound like long-established principles on tax residency and the definition of the management and control test, yet Professor Stewart's analysis puts this aside and states US companies legally incorporated here should be taxed in Ireland on their global operations.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: Is Professor Stewart advocating that Ireland make certain changes unilaterally outside of the OECD base erosion and profit sharing, BEPS, process? What does he suggest, if anything, we do unilaterally as a country?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: Is Professor Stewart advocating that Ireland make any change?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: My final question concerns our corporation tax competitiveness as a country. While there is an important debate taking place in Ireland on the amount of tax multinationals pay and the role Ireland might play in multinationals reducing their corporation tax bills, it seems that our nearest neighbour and competitor, the United Kingdom, has significantly upped its game in terms of its...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: Does he accept the premise that where a company is tax resident determines where it pays its tax?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: That is not the rule in Ireland

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: Are there characteristics of the Irish residency rule that are particular to Ireland? Are we out of step with other countries in terms of our definition of tax residency and the management and control test?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: The professor's main issue is that he is challenging Revenue decisions on where a company is tax resident.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: His analysis seems to suggest that, regarding companies incorporated, he has accepted the US data-----

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: -----that stated such companies have an effective tax rate of somewhere around 2%.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: He accepts that it includes data in respect of companies that are not tax resident here at all. He seems to hold the view that those profits should be taxable in Ireland even though they are not, according to Revenue, and it has decided that the company has a different tax residency elsewhere. That seems to be what the professor is challenging.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: Is he saying that in the case of US multinationals, with operations in Ireland, there should be no distinction between incorporation and residency?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: Yes, tax residency. Is he saying there should be no distinction and if they are incorporated here then they should be deemed to be tax resident here?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: I would like to hear Ms O'Brien's reaction to what Professor Stewart stated. I would like to hear her views on incorporation, residency and the relative importance of from a taxation point of view and impact if we go down the road, as Professor Stewart has said, of eliminating the distinction from a taxation point of view.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: What criteria does Revenue use for the management and control test? Is it common for countries to have a separate tax residency test from the incorporation question?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Assessment of Measures Relating to Corporation Tax in Ireland: Discussion (17 Jun 2014)

Michael McGrath: I welcome Professor Stewart and Ms O'Brien and thank them for their presentations. I will start by asking Professor Stewart questions in order to tease out his main thesis. As he will know, there is a fundamental distinction between the incorporation of a company and tax residency of a company. It seems that the US data, which he has relied heavily on, included in its calculation the...