Results 14,861-14,880 of 34,627 for speaker:Seán Fleming
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: 1 January 2014.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: We will ask Revenue that question.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: I want to ask a few questions that relate directly to Dr. Keegan's presentation. I am following his document. Paragraph 1.4 on page 7 addresses trading income versus passive income. Passive income is generally a term for income derived from investment - rental income from property investments - that is subject to a tax of 25%. For a company to access the 12.5% rate of corporation tax on...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Give me an example of a grey area.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: I will move to a few points on page 14. Taxation of real estate investment trusts is mentioned. It states that shareholders are taxed where a real estate investment trust, REIT, pays a distribution in the form of a property income dividend, and the property income dividend paid to a corporate shareholder is subject to a 25.5% rate. It continues to state that the property income dividend...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Give me examples of who is on 25%, who is on 0% and who is on 12.5%. Perhaps that is what people can relate to. We understood the example about the rental property. Give us an example of this. I know it is an unusual one and Dr. Keegan might not get them all off the top of his head but people can understand this if they can see an example they can relate to.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: It is within a group, essentially.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Next is page 21. I am just moving through them and picking up a few little points as I go. We might put the question on the BEPS action plan of the G20, commenced in 2013, to Revenue. It is stated on page 21 that the purpose of the action plan is to enhance transparency for tax administration, providing adequate information to assess high-level profit shifting and other BEPS-related risks,...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: I am moving on to page 23, the issue of companies paying dividends. I thank Dr. Keegan for his briefing note. That is a matter we will raise in more detail with Revenue in the afternoon. The briefing note was helpful for that. I am moving on to page 26 of the briefing document and the capital allowance relating to intellectual property. We are talking about research and development. I...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Essentially, this allowance is not a self-assessment issue. One must send it in and Revenue can check it. Is it self-assessment?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Revenue does not require an independent audit.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: It only spot-checks it. Does it not require an independent audit? Some of these figures are very significant - hundreds of millions.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: We will take this up with Revenue in the afternoon, and it is quite clear I will tease the matter out in respect of the verification of these hundreds of millions we are talking about. The same paragraph goes on to state:The credit equates to 25% of a company's qualifying R&D expenditure ... The company can also take a deduction worth 12.5% for revenue type R&D expenditure...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: It is an incentive. It is very generous.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: I am moving on to page 28 of the document. I am making it easy for people to follow what I am referring to. I refer to one of the middle paragraphs and to the knowledge box. It states:When a company develops its own IP, and uses that in the manufacture of a product incorporating that IP, the profits on that product are taxed at a special reduced rate. In Ireland that reduced rate is...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Could a company get the benefit of that 6.25% and then get the benefit of the 37.5% reduction as well on the 6.5%?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: In other words - and we will ask Revenue about this - a company's income in respect of this aspect of its activity is taxable only at 6.25%. Is that correct?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Then the company can get effectively a 40% reduction on that 6.5%. That probably leads to a maximum possible effective rate on that level of activity of 3.5%.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: Wow. We have learned something new today about this and we will take that up with Revenue. I know it is a relatively new tax allowance, but the members and witnesses can see why I wanted to raise it. This is how a company can easily get an effective rate combining that 6.25% and that 37.5% write-off on the 6.25%. I move to page 42. I thank Dr. Keegan. He has given us a summary note on...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) Seán Fleming: In other words, for the purposes of our work on corporation tax, that is not an issue as residency is clear for a corporation.