Results 3,221-3,240 of 35,540 for speaker:Pearse Doherty

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: That was an interesting discussion. It related to some of the points I want to touch on. The expectation was that everybody would jump together. There is a level of uncertainty on the implementation, particularly from an Irish context which is important for us in respect of the US. The UTPR safe harbour has been carved out for the US in that instance to the end of 2025. I am conscious,...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: How can we stop it?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: The issue here is the location. We understand the location of subsidiaries is not just an issue in taxation; it is access to markets and all of the rest. The issue relates to subsidiaries based in Ireland of major multinational companies headquartered in America, of which there are many. If the United States does not adopt pillar 2 after 202, the State will be obligated to ensure the Irish...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: That is fair enough, and that is a fair assessment, given that the administration's stated public intention is to sign up to pillar 2. The income inclusion rule, which allows for a parent company to apply the minimum effective tax to a subsidiary in a low tax jurisdiction or a jurisdiction that does not operate under pillar 2, and the UTPR, which allows a subsidiary to charge the tax on the...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Very good. Regarding the safe harbours provisions, Deputy Cowen's amendment dealt with one of them. I understand the point he was making but I do not understand the amendment because it would get rid of the safe harbour provisions, which means we would have to apply the UTPR to American headquartered companies immediately, which would cause a massive clash straight away.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: I appreciate the points Deputy Cowen has made and I understand exactly where he is coming from. The point I was making was that the effect of deleting these lines, from my reading of it, would be to get rid of the UTPR safe harbour, which means that a subsidiary in Ireland would have to apply the UTPR to a parent company in America. This defers that for 12 months to give the opportunity for...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: This provision gives America an extra year because it has a tax rate of 20%. I completely understand the point the Deputy is making.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: As opposed to 2025.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: That is fine. I just wanted it clarified that the QDMTT safe harbour is the permanent position and, therefore, we will not need further changes to how we operate this. I expect that there will be a lot of changes over the weekend. I have mentioned that penalties are being deferred to 2028 to provide time for companies to acquaint themselves with the rules and familiarise themselves with...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Are there no penalties at all or are they deferred? Please explain the reason for no penalties until 2028.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: The Minister has mentioned that it is 18 months to file a return, which means that we will start to see returns in June 2026. Is there not a requirement on Irish entities to fill out a QDMTT within 12 months?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: What about the timeline?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Yes.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Will the Minister clarify that point again? I am sorry, but I did not capture his comments fully.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Yes. I have a question on the digital platform operators and the reporting obligations on them. There are reporting obligations on them where they facilitate the sale of goods or services on the platform. Can the Minister clarify that this does not involve digital platform operators that are involved in the listing of goods or services for sale but do not actually participate in the sales...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: On section 88, I have a concern about this because this measure has been looked for by my own party for many years. Indeed, others have called for a residential zoned land tax, RZLT. There has been delay after delay withy it and it was finally legislated for in last year's Finance Bill. There was a lead-in period that was significant, some would argue. However, there was a process that...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: The UTPR comes in one year after the implementation of the income inclusion rules and then, because of this section, the transitional UTPR safe harbour allows for America to not come under that provision for another year. I do not want to get sidetracked by that. We have discussed the safe harbour provision that is very much aimed at countries that have a tax rate above 20%, and it gives...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Therefore, we should be able to see the level of all three taxes that are generated in future years on a group basis.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: Notwithstanding concerns about implementation in different jurisdictions, and I hope that the OECD's base erosion and profit shifting, BEPS, process will be implemented faithfully by all those who have signed up, it is a significant piece of legislation. When I read in the media that the Finance Bill was going to be €800 I thought about packing my sleeping bag and flask but I was glad...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance (No. 2) Bill 2023: Committee Stage (Resumed) (8 Nov 2023)

Pearse Doherty: There was one question I meant to ask. When this tax is applied to companies under this scope, how much additional revenue is expected to come in as a result of these sections in this Bill?