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Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Is Mr. Cody saying the cost of the research and development tax credit was somewhere near €700 million?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Therefore, those two items alone cost €1.5 billion.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: What was the tax debit or, if one likes, the other half? There was a loss of income to Ireland as a result of that agreement. Were there gains for Ireland as a result of the double taxation agreements?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: I know.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Okay. From a layman's point of view, Mr. Cody has just said the tax credit cost Ireland €900 million, or just short of €1 billion.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: If that was the loss to Ireland as a result of the agreements, which countries were the beneficiaries of the €900 million? Does Mr. Cody understand my question? It is a simple one. If we lost, who gained?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: I understand that.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Has there ever been a stage at which a double taxation agreement resulted in a net flow into Ireland? I can understand what Mr. Cody is saying about now.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: From the point of view of a person watching this, Mr. Cody has just said that this double taxation arrangement has resulted in €900 million less tax being paid in Ireland because it was paid in other countries. Has there ever been a reverse in that situation where Ireland was up €900 million? Is it because our tax rate is lower than other countries'?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: We would have been a beneficiary.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: The US has a higher rate.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Has Mr. Cody any idea of the geography? He is saying that, where some countries have a lower rate than our 12.5%, the cost might generally be borne by them in these arrangements. I am saying this on behalf of the people watching us. They see a cost to the Exchequer of €900 million. Mr. Cody will say that it is difficult to know where it went, given that different countries and...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Mr. Cody might send us a note.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Yes.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: With what Revenue can.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Fine. We have discussed multinationals all day without mentioning any specific one. How many are traditional Irish multinationals? I am referring to large Irish companies that also operate abroad. Has this conversation been dealing with foreign multinationals as opposed to domestic, home-grown, large multinationals that operate worldwide? We know that some Irish companies have a large...

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Of the top 100 companies that the witnesses have been referring to and whose identity we do not know, how many are foreign multinationals versus large Irish companies?

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: Some of the Irish multinationals, for example, Kerry Group, Glanbia and so on, are big by international standards. They are multinationals.

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: They do not feature in our top-----

Public Accounts Committee: Comptroller and Auditor General 2016 Report
Chapter 20: Corporation Tax Receipts
(30 Nov 2017)

Seán Fleming: I am only mentioning them for the purpose of having an example. Very few-----

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