Results 4,841-4,860 of 32,432 for speaker:Paschal Donohoe

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: My apologies to the Deputy if he does not have one. We have some copies here that we can give members.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Absolutely. We will provide it to members. My apologies for that. As I said, it refers to two protocols to the existing DTAs with Isle of Man and Guernsey. Ireland signed the original agreement with the Isle of Man in 2008 and with Guernsey in 2009. The protocols for the Isle of Man and Guernsey were signed on 18 November 2021 and 8 December 2021, respectively. As the members will...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Before I go into the nature of these protocols, I will deal with the Deputy's first question as to why these matters are being dealt with via bilateral amendment rather than through the multilateral instrument. It is up to the Isle of Man and Guernsey to outline why they believe it is in their interest to do it in this way but Revenue and my Department considered it and the view of my...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: My colleagues here inform me that the agreement on the exchange of information is contained in a separate agreement between the jurisdictions. The agreements before us are limited in the scope of their application. As I stated, they only deal with the income of individuals. They contain a mutual agreement procedure for the adjustment of profits of associated companies; that is all. As...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: As to the reason we brought forward the policy statements we published earlier in the week, some of it is informed by my experience of presenting double tax agreements to the committee through several years and some of it by the concerns and perspectives that have been shared here. We are aware of the perspectives that have been raised by stakeholders, especially with regard to our double...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Is the Deputy asking about why companies would be registered in the Isle of Man?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Companies make decisions in respect of locating a presence in the Isle of Man. My judgment is that some of them make those decisions from a tax planning perspective. The agreement we are discussing, however, is a very limited one. It only deals with individuals and the limited business dimension I mentioned earlier. As such, companies that have a holding presence in the Isle of Man do not...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Revenue has informed me these agreements will not affect individuals who might have non-domicile status in the Isle of Man or Guernsey. If the Deputy wishes to have further information on that or a note on it, I will be happy to furnish that to him.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: We are committed to progressing this at European Union level. I believe America will make progress on its global intangible low-taxed income, GILTI, rate as well, so both will happen. Like the Deputy, I will refrain from speculating about what will happen in the US. It is up to them to make the decision but I believe we will see the EU and the US implement this change. A matter we will...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: It could have. Because of the sensitivity of this, I do not want to comment too much on scenarios that could unfold in the future. If America cannot go forward with the implementation of changes in the minimum effective tax rate, it will have a huge effect of where we are overall with the OECD process, not just on pillar 2 but also on pillar 1, because America is so fundamental to it. We...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Not currently. It is always up to us to request the Commission to consider where we are and look at the status of a directive, but the minimum effective tax directive is drafted in a way we believe is compliant with the OECD agreement and represents a fair interpretation of the agreement that was reached. It will be up to us to decide at any point if this should be assessed or reviewed. ...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: If it is not, we will be back to where we were a few years ago.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: I am not aware of any. Generally, the experience of our country has been that they are reasonably positive and beneficial processes to be part of.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: I am, but the Department has been considering what is the best practice for the work we do in the future with regard to double taxation agreements. We are well aware of some of the issues and concerns raised with us, especially regarding our engagement with the developing world. While I would not describe that as a matter for EU concern, we felt it was appropriate and that we wanted to do...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Countries are free to enter into agreements with other jurisdictions as they see fit. That is the whole point of the BEPS process: that we have common standards in place so there is a level playing field on certain aspects of tax co-operation. What this should look like is that, as more and more countries transpose the common standards as we have done through a multilateral instrument, any...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: If Revenue or I become aware of issues we believe are illegal and inappropriate, of course we will respond to them. Can I guarantee the Deputy there is nothing out there that should be of concern to us? In truth I cannot. Tax planning and tax law are immensely complex areas. However, I will go back to the point I offered a moment ago. The value of the OECD agreement is that putting common...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: Of course.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: I thank the Chairman for his long-standing interest in this matter. As he has acknowledged, like the rest of its EU partners, Ireland adheres to the one China policy. As a result, we do not have diplomatic relations with Taiwan. However, this does not preclude the development of economic trade relations. Some of my EU colleagues have negotiated a DTA with Taiwan. At present, my...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: I am sure I will get a view from my officials in a moment regarding who needs to take the next step and where that stands but, as I said earlier in response to Deputy Doherty, we have priorities as regards who we will conclude DTAs with. The current priority is to prioritise G20 countries first. Given that Taiwan is not a member of the G20, I do not expect we will make any immediate...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Agreements: Discussion (29 Jun 2022)

Paschal Donohoe: As I said, I am very much aware the Chairman has raised this matter with me regularly. I appreciate the interest he has in it. I understand, from a correspondence point of view with Taiwan, and a tax perspective, we have responded to the different correspondence it has shared with us. A key issue that is still unresolved is how such an agreement could be concluded and signed. I will be...