Results 15,621-15,640 of 26,610 for speaker:David Cullinane
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: The relevant issues then, are pension contributions, PRSI classifications and possibly allowances write-downs that would not be available to PAYE workers. There is a range of issues.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I do not want to be unfair to anybody, and I note that it is not illegal. By and large, however, I would imagine that, from an individual's perspective, the motivation would be a reduction in tax liability. Would that be a fair assessment?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I saw that.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Okay. I thank Mr. Cody for that. I have a very quick question on Apple, which I know Mr. Cody has dealt with. He has said that Revenue is 99% of the way there in terms of calculating the liability. I imagine that, even though it is only two companies, Revenue will be going back over time. What is the time period it is looking back into?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: That would involve any payment which could be perceived as state aid to either of the Apple companies involved. What types of payments would they be in broad terms?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am not looking for the figures. I am asking whether it is to do with how their taxes were calculated or to do with write-downs, incentives and so on.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Forgive me if I am wrong, but was the judgment not that there was a special arrangement for Apple in terms of state aid rules which did not apply to other companies? Was that not the substance of the Directorate General's judgment? Perhaps the Department might have an answer to that question.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: It is not that tricky because the judgment was very clear. The judgment was that favourable treatment was given to Apple. Was that not the essence of the Commission's judgment?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: It was made in terms of state aid.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: And the Department is appealing that judgment.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am just trying to understand the calculations. If all state aid which was given to those two Apple companies is being calculated, I would imagine that similar state aid was given to other companies, was it not? I am trying to establish what exactly the Department is looking at to arrive at whatever figure it will arrive at. I am sure it will be greater than €13 billion. Is it...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Perhaps I can put if differently to help the witnesses understand me. I put this question to Mr. Cody. The judgment is that the State did not collect enough tax from Apple. That judgment was because of what the Commission saw as favourable state aid rules being applied to Apple, a special arrangement or whatever way one chooses to phrase it. That was the substance of its judgment, which...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I understand that.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Yes, I understand that.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: However, Revenue is obviously using a methodology to calculate this figure.
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: Will Mr. Cody explain that methodology to me?
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I appreciate that. I understand the point that Mr. Cody is making that, although this ruling will be tested in the court, it is a decision of the Commission and Revenue can only calculate a figure in respect of the two companies before it on the basis of that decision. I am just surmising that if a similar exercise were carried out on other companies using the same methodology, it is...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I am not asking Revenue to do it, I am-----
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: I will finish with the special report of the Comptroller and Auditor General. There is a quote which has been dealt with but on which I have some questions, "eight of the 100 companies with the highest taxable income had an effective tax rate of zero, including some who had negative rates", which are cases in which rebates were paid, "A further five had an effective rate of less than 1%."...
- Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts (Resumed) (22 Feb 2018) David Cullinane: They would have paid tax in the other country.