Results 29,741-29,760 of 35,924 for speaker:Pearse Doherty

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: Consequently, as a body, Revenue would have been aware that the company in question at the hearings was not tax resident anywhere in the world.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: This is interesting because the question arises as to whether the company in question did or did not tell Revenue it was tax resident somewhere else at the time. I acknowledge that the delegates cannot provide members with that information because it is confidential and I do not expect it to receive it. However, I tabled a parliamentary question to the Minister for Finance asking how many...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: We do not know how many companies are using this state. They are incorporated in the State, not paying any tax in the State and not paying any other tax. They are using our system because we deem tax residency to be based on control and management and such companies are exploiting the difference between us and others. However, we do not have a clue as to how many companies are involved....

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: The other claim one hears continually which I have heard again today and from Government sources is that we do not do special tax rate arrangements. No one is making that accusation. I have not heard anyone make that accusation against the State. The accusation, right or wrong, is that there are special arrangements. I hear the delegates continually deny a charge that has not been put....

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: That is the entire point, namely, whether the State facilitates arrangements. Perhaps the Revenue Commissioners are only implementing what is contained in the Finance Act and the question arises as to who has influence in the drafting of legislation to facilitate such companies. However, I will turn to the issue of the transfer of royalties. While there has been much emphasis on the...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: Let us deal with BEPS. I hope the global architecture will be of assistance in resolving this matter. It is the best way to proceed, especially in light of the specific interests of particular countries. Let us focus on the fact that certain companies incorporated in Ireland make billions of euro in profits and do not pay any tax to this State or any other. What are we going to do about...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: The 1998 report compiled by the Department was very good, particularly because it examined the various loopholes. It is the job of companies to exploit loopholes and it is our job, as legislators, and that of the Department of Finance to close them. In 1998 the tax residency rules for companies were changed because it became evident that they were exploiting them. It was decided then that...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: Mr. Tobin is right and it was effective in the context of dealing with that issue at the time. Another situation has arisen 15 years later in that, as everyone present is aware, there are companies which are registered here and which do not pay tax anywhere in the world. Would it be possible to include in the forthcoming finance Bill a mechanism similar to that which was used in 1998? It...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: So there is no truth in the report to the effect that the Department was seeking to clamp down on the double Irish and that either the formal investigation or the request for information scuppered that plan.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: The following statement was given by an Apple representative to the Senate sub-committee hearings: Since the early 1990s the government of Ireland has calculated Apple's taxable income in such a way as to produce an effective rate in the low single digits. The rate has varied from year to year, but since 2003 has been 2% or less.That statement is contained within the exhibits relating to the...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: Unfortunately, the clock is ticking in terms of the time allotted to me for questions and answers.

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: I am well aware of the tax code in regard to small companies. The statement to which I referred was made to the Senate hearings by a representative of Apple. That company provided a lot of information to the hearing over a number of weeks because it was the case study. In disputing the claim, Mr. O'Dea is effectively saying it was blatantly wrong. Does he accept that?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: Yes, that is very interesting. Can Mr. Tobin confirm whether he was the official in the Department of Finance who telephoned Apple after the hearing recommendations emerged? It is a matter of public record, as indicated by the Minister for Finance, that telephone calls were made to Apple after the publication of those recommendations on 21 May. The CEO of Apple subsequently indicated that...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: Is Mr. Tobin saying the call was unsolicited on a political level, that it came from the Department itself?

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: The company in question has a relationship with the Department of Finance in that its representatives would have met senior departmental officials under previous Governments. I find it astonishing, however, that the Secretary General of the Department would make a suggestion to the company that it should approach the Government to discuss improved adoption of Apple's products. Would it be...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: I accept that such meetings can be entirely innocent. I am aware that the Secretary General has met representatives of the company in question on two other occasions to discuss ICT, knowledge performance and so on. My question relates to the relationship between the company and the Department. It comes down not to the tax rate but the arrangements between the Department and certain...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: What Mr. Tobin has described is perfectly normal and innocent. Companies tender for e-Government contracts all the time. It is increasingly the direction in which we are moving. That, however, is completely different from the issue I am raising today, as outlined in the documents before me and on the basis of the freedom of information request I submitted. The issue is that the Secretary...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: I am a little disappointed that the Revenue has not placed its submission on the record although it is available from the Department of Finance. However, I would have liked to have seen Revenue's submission considering that Revenue is central to these hearings. Perhaps the submission could be furnished to the committee later because members are asking questions blindly. Since the early...

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: If I may begin again. Since the early 1990s the Government of Ireland has calculated Apple's taxable income in such a way as to produce an effective rate-----

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation: Base Erosion and Profit Shifting: Discussion with Department of Finance and Revenue (18 Sep 2013)

Pearse Doherty: -----in the low single digits-----