Results 24,201-24,220 of 33,044 for speaker:Catherine Connolly

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...

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

Catherine Connolly: I understand that. I only wanted to get it clear in my own head. It was accepted that the company was stateless. The company that took in most of the profit would pay tax nowhere. Is that right? Take it away from Apple, call it Orange, or anything Mr. Cody likes. In other words, other companies could have been doing exactly the same.

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

Catherine Connolly: I am not asking-----

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

Catherine Connolly: I will. Okay.

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

Catherine Connolly: Mr. Keegan presented a paper this morning and updated us. He was a fairly neutral person when he set out, taking ASI as an example, that the ruling allowed a split of the profits recognised by ASI in Ireland. The majority of profits were allocated to a head office within ASI with the remainder and so on, and Irish corporation tax was applied to the profits of the Irish branch. The head...

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

Catherine Connolly: No, that is-----

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

Catherine Connolly: That is okay.

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

Catherine Connolly: I will go back to a general point. Before all things changed utterly in Ireland, am I wrong in saying other companies were doing exactly this? They had head companies that were stateless. Is that right? That has changed completely.

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

Catherine Connolly: I know and Mr. Cody is very consistent about that and I am not questioning it. My question is addressed to anybody here. Were other companies doing the same thing, or could they have been? Under the existing law in Ireland there could be a stateless company getting most of the profit and not paying tax anywhere. Am I wrong?

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

Catherine Connolly: No, I do not want to know about the change. I know there has been a change. I want to know the position then. Were companies doing this and were they allowed to do it before the changes came in? Is that a difficult question?

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

Catherine Connolly: No questions were asked because there was no need to ask questions under Irish law at the time.

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

Catherine Connolly: Or no country, more to the point. It is not the difference between different countries but between a country and no country.

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

Catherine Connolly: I will not hammer the point. I have made it. My last point was about residency. Could Mr. Cody please talk me through the residency conditions of 183 days? How do we get the information? Do we know how many individuals are benefiting from the rule or are outside it? Could he put an individual's tax residence in context for me?