Results 7,461-7,480 of 33,175 for speaker:Paschal Donohoe

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 35: In page 50, to delete lines 10 to 15 and substitute the following: “ “(iii) under section 835AAE for total spare capacity (within the meaning of Part 35D) arising to the company in an accounting period beginning before the change of ownership for any accounting period after the change of ownership.”.”. I am introducing several...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I will try to deal with the different questions put to me by Deputy Farrell. On the question regarding the orphan structure and the stand-alone company, as the committee will be aware, an orphan company is a company that is bankruptcy remote. This means that in the event of a bankruptcy, the assets of the securitisation company are ring-fenced against the liabilities of that company. The...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: On the question regarding the financial instrument, if it was issued before that date and unchanged, it would be exempt. After that date, if the terms are changed in any way, it would then be subject to this new rule. On perpetual bonds, they do not fall into this legacy exemption. As milestones for drawdown must be included in the terms of the bond, they do not fall into this exemption....

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: Yes, it is that directive. The anti-tax avoidance directive, or ATAD, provided for a general transposition date of 1 January 2019, but it was also specified that where member states had pre-existing rules relating to interest deductibility that were equally effective at preventing BEPS risks, implementation could take place up to 1 January 2024. My view, which is supported by the analysis...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: It is important to put our efforts on ATAD transposition into context. There were many other elements of the ATAD that were equally important and that Ireland fully delivered on time, for example, changes with regard to exit tax, control of foreign companies, hybrids and the work we have under way in this Finance Bill with regard to reverse hybrids. It is the case that while we delivered...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: That is the key issue I am aware of. If any other issue has been raised that is of equal importance and which I am not aware of, I will share it with the committee. That is the key issue that was raised.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: Yes.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 36: In page 53, to delete lines 21 to 26 and substitute the following: “(v) such portion of the profit or loss on- (I) a financial asset (within the meaning of section 76B), or (II) a financial liability (within the meaning of section 76B), the coupon or return on which principally comprises interest or one or more of the amounts referred to in this...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 37: In page 53, between lines 26 and 27, to insert the following: “(c) any amounts referred to in paragraph (a) or (b) claimed by a claimant company under section 420(6),”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 38: In page 53, line 27, to delete “(c)” and substitute “(d)”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 39: In page 53, line 27, to delete “incurred” and substitute “arising”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 40: In page 53, line 32, to delete “(d)” and substitute “(e)”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 41: In page 53, line 34, to delete “(e)” and substitute “(f)”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 43: In page 54, line 30, to delete “resources” and substitute “sources”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 44: In page 55, line 11, to delete “the portion of”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 45: In page 57, to delete lines 34 to 40 and substitute the following: “(b) any relief for losses or excesses, as the case may be, carried back from a subsequent accounting period under section 396(2), 396A(3), 396B(3), 397(1) or 399(2), or (c) amounts set off under section 420 (other than interest treated as a charge on income that may be set off under...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 46: In page 60, to delete lines 16 to 32 and substitute the following: “Capallowis the amount of allowances in respect of capital expenditure under Parts 9, 24 and 29 made to a relevant entity, and the amount in respect of the non-finance element of finance lease payments deducted in calculating that entity’s relevant profit or relevant loss, as the case...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 47: In page 61, to delete lines 26 to 36 and substitute the following: “(c) in a case in which an amount of deductible interest equivalent is deducted against chargeable gains chargeable to tax at the CGT rate, the amount of that deductible interest equivalent shall be adjusted as follows: IEded-adj = IEdedx (T rate/CGT rate) where- IEded-adjis the...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 48: In page 62, to delete lines 32 to 43, to delete page 63, and in page 64, to delete lines 1 to 39 and substitute the following: “Carry forward of disallowable amount 835AAD.(1) Where section 835AAC applies to a relevant entity for an accounting period (in this section referred to as the ‘first-mentioned accounting period’), the relevant...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2021: Committee Stage (Resumed) (17 Nov 2021)

Paschal Donohoe: I move amendment No. 49: In page 68, line 10, after “enterprises” to insert “which gives rise to deductible interest equivalent”.