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Written Answers — Department of Finance: Revenue Commissioners Investigations (24 Nov 2016)

Michael Noonan: I am informed by Revenue that they have been engaged since 2014 in a compliance program that involves visits to pension providers, pension administrators and pension trustees in relation to the transfer of pension funds off-shore. The objective of the compliance program is to ensure that the purpose of any transfer of pension funds off-shore is for bona fide reasons and does not contravene...

Written Answers — Department of Finance: Fiscal Policy (24 Nov 2016)

Michael Noonan: Given the continued relatively weak recovery in the euro area as a whole, the European Commission is recommending that a modest fiscal expansion be undertaken in the euro area. An expansion of up to 0.5 per cent of GDP is recommended by the Commission.  It is crucial to stress that the Commission recommends that this expansion be differentiated by country and, in particular, with...

Written Answers — Department of Finance: Tracker Mortgage Data (24 Nov 2016)

Michael Noonan: The Central Bank is undertaking an examination of tracker mortgage related issues covering among other things transparency of communications with and contractual rights of tracker mortgage customers. The Tracker Mortgage Examination remains a key priority for the Central Bank as it continues to challenge lenders to ensure that progress is being made and fair outcomes are being achieved for...

Written Answers — Department of Finance: Central Bank of Ireland Staff (24 Nov 2016)

Michael Noonan: Please find in the following table the total staff numbers in the Central Bank for each year from 2008, to 31st October 2016. These are calculated on the basis of total full time equivalents. Year FTEs 2008 1,022 2009 1,044 2010 1,226 2011 1,372 2012 1,394 2013 1,384 2014 1,364 2015 1,516 2016 (31st Oct) 1,597

Written Answers — Department of Finance: European Central Bank (24 Nov 2016)

Michael Noonan: 54 Central Bank staff are currently seconded to the European Central Bank. There are no Department of Finance staff currently seconded to the European Central Bank.

Written Answers — Department of Finance: Financial Institutions Inspections (24 Nov 2016)

Michael Noonan: Since the commencement of the Single Supervisory Mechanism (SSM) in November 2014, a total of 35 onsite inspections have been carried out on Significant Institutions and Subsidiaries of Significant Institutions in Ireland.  Of these 35 inspections, 3 have been led by a Head of Mission from within the SSM but outside Ireland and in the case of these three inspections the...

Written Answers — Department of Finance: Departmental Agencies Staff Data (24 Nov 2016)

Michael Noonan: In response to the Deputy's query please find, in tabular form, details of the number of vacancies on State boards under the aegis of my Department; the number filled since 6th May 2016; the number filled through the Public Appointments Service; the timelines to fill vacancies.  All appointments to State Boards are made in conjunction with the State Board Appointment process. ...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I gave the commitment the Deputy is requesting when we discussed it with amendment No. 26.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The nature of the commitment is I will give Deputies a full briefing note on the issues raised by a number of colleagues when we discussed amendment No. 26.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The effect of the proposed amendments would be to require Revenue to publish the country-by-country reports filed under section 891H of the Tax Consolidation Act 1997. Section 23 of the Bill simply makes minor amendments to country-by-country reporting as introduced last year. These minor amendments are to ensure our legislation is fully consistent with the EU directive agreed after we had...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The point of what I read out is that country-by-country reporting arises from an OECD recommendation under its BEPS project. It was accepted internationally. Last year, country-by-country reporting was enshrined in law in accordance with our international agreement with all other OECD members. Part of the international agreement is that while there would be an exchange of information...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Loans by connected persons to other connected persons will be allowed in general. We would not make an exception in this case provided everything is kosher in the arrangements between them.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Yes. An internal loan is allowed as long as the rate is the same as a commercial third party loan.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: The tax code taxes persons on the profits which they earn. Profits are calculated after taking account of deductions incurred wholly and exclusively in the course of the business from which the profits arise. The Irish tax code does not generally disallow a transaction between connected persons where that transaction is carried out on the same terms as a transaction with an unconnected...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Yes. The charity issue was exaggerated in the coverage of the section 110 issue. It is an accident of Irish law that they are the only trusts available but it was as described in the speaking note. As I stated, this is extremely complicated and we will provide the Deputy with answers to her questions.

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I move amendment No. 36:In page 40, to delete lines 34 and 35 and substitute the following:"(c) a loan origination business, (d) a sub-participation transaction, or (e) activities which are preparatory to the transactions or business mentioned in paragraphs (a) to (d),".

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I move amendment No. 37:In page 41, to delete line 1 and substitute the following:"distribution payable thereon; 'sub-participation transaction' means a transaction which involves the acquisition of an economic interest in a loan by the qualifying company in the ordinary course of a bona fide syndication of such loan to one or more lenders where the originator of the loan— (a) is a...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: I will deal with the question on charities. In certain financial transactions it is common practice for the shares in a special purpose vehicle, SPV, to be owned by a charitable trust. In Ireland the only type of purpose trust is a charitable trust. This ensures, first, that the SPV is not consolidated into the accounts of the originator, thereby ensuring the originator is in a position to...

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: It is very hard to say anything credible in two minutes. If I take Deputy Richard Boyd Barrett's question-----

Finance Bill 2016: Report Stage (Resumed) and Final Stage (23 Nov 2016)

Michael Noonan: Deputy Richard Boyd Barrett asked why we had this provision in place. Some 38,000 people are employed in the financial services industry in Ireland. It is a sector that is expanding and we think it will expand rapidly in the short to medium term because of the relocation of activity from the City of London as a consequence of Brexit. Section 110 of the Taxes Consolidation Act 1997 is...

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