Results 12,561-12,580 of 35,658 for speaker:Pearse Doherty

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: Are there any plans now?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: The Minister says the primary change in the agreement is the anti-avoidance issues. In particular, the new double taxation agreement includes the principal purpose test under base erosion and profit shifting, BEPS, under action 6. He goes on to state that the test ensures that any benefits under the double taxation agreement are denied if the main purpose of the arrangement is the avoidance...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: It is needed and will be a big improvement in these two taxation agreements, but does it exist in the Luxembourg agreement?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: When is that likely to take place?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: November of this year?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: The general anti-avoidance rule, GAAR, has been on our Statute Book for many years and has been updated in different Finance Acts. It is very clear that where an arrangement's primary or main purpose is avoidance of tax, the benefits will not accrue. Is that correct?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: If, for example, a business were to change its residency from Ireland to Luxembourg and the main purpose of that was tax avoidance, that would be deemed tax evasion under our existing law and the GAAR because it would be illegal and therefore the benefits would not apply. Would that be correct?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: I am not asking about a change like this. I am asking about our existing law because this does not apply to all other agreements. Under the GAAR if a company were to transfer or change its residency from here to another jurisdiction, for example, Luxembourg, for tax purposes, it would not benefit from-----

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: Until that is signed it is our law that would apply and therefore it would not get that benefit. If a company, for example, transferred assets to another jurisdiction and then supplied loans to this country that allowed it to write down its profits but that transfer arrangement was made, without any treaty or bilateral agreement, to reduce its tax liability to zero or next to zero, our law...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: I will be very quick on the rest of this. There is a nuance in our existing law. When this agreement is signed and ratified with the Netherlands and Switzerland and with the others, including Luxembourg, later this year, will it then consider the permanent establishment of existing companies or will it just apply to new establishments that are changes in residence applied after that date? ...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Double Taxation Relief Orders 2019, Swiss Confederation and Kingdom of the Netherlands (2 Jul 2019)

Pearse Doherty: We have seen in the newspapers today that a company can be established with no employees but which provides loans to a company in Ireland - the location of the parent company - and this facilitates a write-down of tax. It will be deemed as permanently established in another jurisdiction despite the fact it has no operation or employees there. How can a company be run without employees?...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: The Minister is aware that I have already raised the issue of the credit union levy in parliamentary questions. He is also aware that for several years, I have argued that there should be 100% recovery in the banking industry. I am glad that this is now taking place. In his opening statement, the Minister said he recognised the unique nature of the credit unions. It is important to...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: First, it is not 50% full stop. It is 50% and then there will be a consultation to see what happens after the 50% levy is raised. There is no guarantee, unless the Minister wants to give one here, that it will be only 50%. Will the Minister give that guarantee first, as it would clear up some of the other issues I have?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: The Minister said he agrees with me but really he does not. I am arguing a different point. The Minister has stated he agrees with me and that is why he has asked the Central Bank to phase in the increase. All that is happening is that it is being done at a slower rate. The levy will go to 50% and then there will be a consultation with, as the Minister just outlined, no guarantee that it...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: Prior to 2012, what did the high street banks pay for regulation costs?

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: It was 50%. The banks paid 50% towards the cost of regulation. The Government phased in a process over time to recover 100% of these costs. Seven years ago, Bank of Ireland, AIB, Ulster Bank and the rest, some of which crashed the economy, paid 50% towards the costs of regulation. Now, we will ask the local credit union, which is volunteer-led, responds to the needs of the community and...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: Seven years ago, Bank of Ireland paid 50% towards regulation costs.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: The Minister cannot give a guarantee that in seven years’ time, the credit unions will not be paying the full 100%. Even after the crash, the banks were paying 50%. I always argued that was wrong and they should have paid 100%. The point is that the Minister is now putting credit unions on such a trajectory. He is not recognising their unique value and nature. He can argue that...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: I have one further question.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Credit Union Sector: Discussion (2 Jul 2019)

Pearse Doherty: Can we not introduce it in the Finance Bill?