Results 15,201-15,220 of 26,902 for speaker:Richard Boyd Barrett

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)

Richard Boyd Barrett: No. The suggestion, which is very clear and which I think Mr. Cody understands fully, is that all of us find it simply incredible - not credible - that Revenue did not notice quite some time ago, long before 2013, that a company that was incorporated here was stateless, that the profits from a company that did have a real economic presence here were being siphoned into the stateless company...

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)

Richard Boyd Barrett: Revenue did not flag 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)

Richard Boyd Barrett: 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)

Richard Boyd Barrett: Therefore, the-----

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)

Richard Boyd Barrett: That is my point. Mr. Cody is saying the US Administration knew beforehand. If any reasonable person saw that an incorporated company was either resident in the Cayman Islands or stateless - certainly if Revenue did - he or she would think there was something going on there. We are a little surprised that Revenue did not flag this - or did Revenue flag it way back when, when it became...

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)

Richard Boyd Barrett: I ask Mr. Cody to remind me, as a matter of interest, when the criteria of ownership and control, the distinction between a tax resident and an incorporated body, were introduced in legislation.

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)

Richard Boyd Barrett: I will move onto another aspect of this because one can come at it from many different ways. If Niall Cody develops a phone and holds the intellectual property for that phone and if he sells the intellectual property to me, the profits I generate from selling the phone accrue to me, do they not?

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)

Richard Boyd Barrett: Did Apple Inc. have the intellectual property rights for the sales of Apple products in Europe, Africa and Asia? Mr. Cody referred to them and kept saying, as the Minister has said, that we know Apple Inc. was managed in and controlled from the United States and that that is where the intellectual property was developed. However, it is irrelevant whether it was developed there. The issue...

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)

Richard Boyd Barrett: Who did have them? A company incorporated in Ireland but not tax-resident in Ireland had them. Is that not 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)

Richard Boyd Barrett: We will move onto that, but I think we have clearly established that Apple Inc. did not, so it is a complete red herring for anybody to talk about it developing the intellectual property or in any way the tax being owed to it because it had sold the intellectual property to another company, which was incorporated in Ireland but not tax-resident in Ireland. Mr. Cody himself referred to ASI...

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)

Richard Boyd Barrett: Therefore, the branch, which has thousands of employees, an office, a headquarters and so on, is a branch of this company that holds the intellectual property rights but which has no staff and no office, and Mr. Cody says it carries out routine functions. What routine functions does it carry out if it has no staff and no office?

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)

Richard Boyd Barrett: He did.

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)

Richard Boyd Barrett: I am reading from his statement.

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)

Richard Boyd Barrett: It refers to "these routine functions."

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)

Richard Boyd Barrett: No, I-----

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)

Richard Boyd Barrett: What I fail to believe or find credible is that Revenue could accept from Apple that this company, which is incorporated here but not tax-resident here, has any economic reality that would allow the branch to allocate the profits to 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)

Richard Boyd Barrett: May I ask Mr. Cody a very short question about that? My time is nearly up. Even on that basis, which I do not accept-----

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)

Richard Boyd Barrett: No, I do not accept that it is credible-----

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)

Richard Boyd Barrett: I do not accept it as credible. Even on that basis - and I think this is more or less what the CCTB attempts to do - even when Revenue was trying to assess what the Cork branch did, I think a reasonable understanding of this is that there is a place where the intellectual property is developed, then there is a hub for selling that intellectual property and then there are the countries into...

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)

Richard Boyd Barrett: How does Revenue-----