Results 1,301-1,320 of 27,019 for speaker:Michael Noonan

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: It is Europe, the Middle East, India-----

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The answer is "No".

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: It would be more accurate to say we are being asked to collect tax on profits accruing to Apple for economic activity that was outside the island of Ireland.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: I am not going to go down that road now. There is a court case.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: I am not here to speak for Apple. I communicated with the clerk to the committee that, because of the legal cases, I am constrained in what I can say. The Deputy is trying to push me into a position where an answer of mine could be used in evidence at the appeal. I am not going to go into that position.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The Deputy has made the point.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: From my perspective, the Deputy's statement is not the issue. The Deputy is cross-examining on the basis of the thesis that the Commission was right in its findings. He is bringing forward evidence of how Apple was structured to prove it was right. He is saying that under state-aid and tax rules, the liability is with Ireland. I am saying I cannot enter that debate with the Deputy because...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The Deputy is arguing the Commission's case but he is not before the court. I will not get into that space.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The Deputy is arguing that the Commission was right and that the Irish authorities should not appeal its decision.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The intellectual property at the time was not in Ireland and, therefore, it was not attributable to the Irish branch. That is the central point of the case. I came here with the full understanding from the Chairman that we would not prejudice the case. The Deputy is asking me to take a position on the case in agreeing with him when, effectively, he is arguing the Commission's side of the case.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: More information would be needed before a tax ruling could be given on that. This is not cut and dried. Issues of where the company is controlled from would enter into it.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: Yes they would be taxable in Ireland but there could be relief from foreign tax as well.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: I am not here to give tax opinions.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: No we are not. We are talking about the Deputy trying to get me to say things that can be used against Ireland in the appeal and I am not going down that road.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: I think in our dialogues over the years I have succeeded in rubbishing the Deputy's views more often than he has succeeded in rubbishing mine.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: That may be so but it could also be that no records were retained. It is not a matter for me. The Chairman of the Revenue Commissioners will be here very shortly and the Deputy can ask him the question. This goes back 25 or 26 years in the Revenue Commissioners. How can I answer the question?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: First, it was the Government that took the decision to appeal and it did it on my advice. Second, the decision was put to the Dáil and a very big majority in Dáil Éireann supported the decision to appeal. I do not have the numbers now but that is the position.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: That is a very big majority. They are the three mainstream parties. I know the Deputy is ambitious to have a big party but the reality of the arithmetic is-----

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The reality of the arithmetic is that Fianna Fáil, Fine Gael and Labour have a very big majority in the Dáil and that is what they decided because it was in the best interests of the country. Commissioner Vestager is a very impressive lady but she is on the other side of this argument and we are appealing against the decision made by her and her officials which affects Ireland,...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: The reality is that this is a classic BEPS scenario arising from the mismatch between tax laws in two different jurisdictions. Although the profits concerned were generated in the United States, that country did not tax them as the companies were not incorporated there. In line with the tax treatment of non-resident branches internationally, the Irish law focuses exclusively on the profits...