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Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: I thank the witnesses for attending and thank Mr. Cody for his presentation. In true Revenue style, Mr. Cody answered in his own brief words several of the obvious questions which arise and I may well be briefer than the 20 minutes. How did Revenue become aware of the existence of a tax planning strategy specific to consultants? Was it a tip off or does Revenue have a network of...

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: It was a random-----

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: No. The Revenue uses analytics to choose people or whatever. From that, as Mr. Cody stated, the Revenue decided to take a look at this to see whether it was replicated, and it was. They expanded the project into a national project and they are where they are now. As part of his investigations, did Mr. Cody identify who devised this strategy? Who was it, or can Mr. Cody tell us?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Was the scheme, to the knowledge of the witness, targeted specifically at consultants?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: The witness mentioned the Irish Medical Organisation, IMO. Is it safe to say it was not the representative organisation, the medical organisation-----

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: It is about imposing it here. For all the world, this would have been reputable professionals coming up with a scheme and recommending it. In essence, the scheme was illegal or, if appropriately used, was it legal?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Would the witness say the design of this scheme was prudent tax planning and management in line with the law or, notwithstanding the fact that the project is still under way, does he believe the scheme was designed to subvert the law in terms of tax?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: It probably is too good to be true.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Is there a possibility of other professionals or consultants utilising similar strategies?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Is it becoming the practice in sectors that there are aggressive avoidance schemes? Is that becoming the norm?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: An internal working group was set up to look at the matters from a corporation or professional practice standpoint, with a view to publishing guidance. Is that work complete?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: There is no information available from that just yet.

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: I have another point. Of the 403 cases, one third had no yield. Is there information on the types of intervention on the no-yield cases? Was it aspect query, profile interview, audit, for example?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Is that foolproof? Is it fair to say the 121 cases were not audited?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: In terms of outlay for the Revenue Commissioners in a case that is being investigated, is there a difference between cases that yield and that do not?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: In respect of the two cases in which the Comptroller and Auditor General identified incorrect calculations of penalties and interest, have the Revenue Commissioners identified why that happened? Are there more robust procedures to ensure it cannot happen again?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Have steps been undertaken?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Has Revenue got sufficient resources for optimum output?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: More specifically, if Revenue had more people would yields be higher? Would there be a higher level of tax compliance?

Public Accounts Committee: 2015 Annual Report of the Comptroller and Auditor General and Appropriations Account
Chapter 13 - Revenue's Review of Medical Consultants' Tax Affairs
Chapter 14 - Research and Development Tax Credit
Chapter 16 - Deferral of Tobacco Stamp Liability
(1 Jun 2017)

Marc MacSharry: Revenue has not been refused any request for additional resources.

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