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Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 50: In page 60, line 28, to delete “subsection (1)” and substitute “subsection (2)”. I am bringing forward several amendments to section 30 which introduces new ATAD-compliant anti-hybrid rules to Irish legislation. The majority of the amendments which I am proposing to the section correct drafting, cross-reference and typographical errors...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 51: In page 60, line 31, to delete “subsection (1)” and substitute “subsection (2)”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 52: In page 61, line 2, to delete “subsection (1)” and substitute “subsection (2)”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 53: In page 61, line 11, to delete “This section” and substitute “Subject to subsection (3), this

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 54: In page 61, to delete lines 15 to 17 and substitute the following: “(a) the head office of the entity and a permanent establishment of that entity, (b) two or more permanent establishments of the entity, (c) where the entity is a participator in a hybrid entity, the entity and the hybrid entity, or (d) where the entity is a participator in two or more...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 55: In page 61, to delete lines 23 and 24 and substitute the following: “(b) a payment is deductible in a case in which—”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 56: In page 61, to delete lines 29 to 32 and substitute the following: “but for the fact that the amount against which the payment is deductible in the payer territory is a disregarded payment in the first-mentioned territory, the disregarded payment shall be treated as included in the first-mentioned territory. (3) This section shall not apply...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 57: In page 63, line 3, to delete “foreign” and substitute “domestic”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 58: In page 63, line 6, to delete “domestic”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 59: In page 63, line 8, to delete “domestic” and substitute “foreign”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 60: In page 64, line 9, to delete “paragraph (a)” and substitute “paragraph (b)(i)”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 61: In page 65, to delete lines 13 to 18 and substitute the following: “(a) dividends and manufactured payments, (b) interest, including any discounts or amounts which would be treated as interest under Part 8A, notwithstanding that no election is made under section 267U, (c) the amount of payments that are equivalent to interest under an arrangement...

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 62: In page 66, line 26, to delete “the payment is not” and substitute “a corresponding amount has not been”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 63: In page 66, to delete lines 33 to 37 and substitute the following: “(I) in a case in which the non-inclusion arises because of any provision of the Tax Acts or the Capital Gains Tax Acts, in calculating the amount on which the payee is charged to tax, that provision shall be disapplied, insofar as it provides for the non-inclusion, and”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 64: In page 67, line 32, to delete “the payment is not” and substitute “a corresponding amount has not been”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 65: In page 68, line 13, to delete “the payment is not” and substitute “a corresponding amount has not been”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 66: In page 70, line 9, after “tax” to insert the following: “for so much of the payment as corresponds to the mismatch outcome which has not been neutralised in another territory”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 67: In page 71, line 3, after “deduction” to insert “for the purposes of domestic tax”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 68: In page 71, line 23, to delete “835AH” and substitute “835AI”.

Select Committee on Finance, Public Expenditure and Reform, and Taoiseach: Finance Bill 2019: Committee Stage (5 Nov 2019)

Paschal Donohoe: I move amendment No. 69: In page 71, line 37, after “deduction” to insert “for the purposes of domestic tax”.

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