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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)

Gerry Horkan: I wish to make a couple of points. To follow on from Senator Burke's question on selectivity, the Commissioner referred to how Apple did not pay the corporation tax rate of 12.5% and that the Commission was basing its case on this and the idea that the tax ruling was selective. The Commission's argument is that Apple got a special deal. According to the Commissioner, the somewhat...

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)

Seán Sherlock: At the joint committee meeting she attended recently, the Commissioner stated:I can say how it looks from my side. We did not investigate how Apple organised its operations. We did not investigate the cost-sharing agreements. We did not investigate the fact that Apple records its profits in Cork, Ireland. We were looking at whether the allocation of profits was recorded in the branch and...

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)

Pearse Doherty: It might sound very plausible to people out there when the Minister comes to the committee and asks why should we tax sales of Apple products in Spain, the US or wherever. We know the US taxes the sales of products in the US, Canada and the rest of America. That has been identified. In all of the other jurisdictions, why did Apple structure itself in this way? I will rehash what Mr. Tim...

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)

Pearse Doherty: ...rights. We are talking about economic rights and not intellectual property. I would appreciate if the Minister answered the questions. My contention is that economic rights for all sales of Apple products outside of the Americas rested with an Irish-registered company. That would not alter the Commission's argument one iota. The Commission's argument is that because of where 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)

Paddy Burke: When the European Commissioner attended, she stated that, as a result of the Apple case, the Commission examined 19 other Irish companies and found nothing wrong. The Apple case was different. Would Revenue not have seen that difference as well?

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)

Gerry Horkan: Apple went into the US Senate and said what it said. How does Revenue reconcile what Apple said with its own view or is it possible to reconcile the two?

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)

Pearse Doherty: I welcome the Minister. We received his statement very late. He mentioned that Ireland was asked by the Commission to collect the tax on Apple's worldwide profits. I challenge that statement. Is it the Commission's suggestion that we tax Apple's profits on products sold in the United States of America?

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)

Pearse Doherty: This is a statement of fact. This is not a dispute. Apple had structured itself from the 1980s with an Irish-registered company owning the intellectual property for all products sold outside the Americas. Is that not a statement of fact? Did representatives of Apple not say that in the US Senate hearing?

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)

Rose Conway Walsh: ...here with the restrictions that are around it. However, I think we need to address a few things. The transcripts which this debacle centres around speak for themselves. On 30 November 1990, Apple's tax adviser met with Revenue Commissioners and stated that the company would be prepared to accept a profit of between £30 million and £40 million for taxation in Ireland as...

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)

Michael Noonan: The discussions are ongoing with Apple, and it are co-operating. If it did not co-operate we could take enforcement proceedings in the Irish courts and have the force of law to collect, but we are not going there. We think that as the details are resolved, Apple will transfer money to the escrow account.

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)

Paddy Burke: When the Commissioner was here, she stated that the Commission sent out circulars to 19 other Irish companies with the same questions that it would have sent to Apple. The Commission stated that in the other 19 companies it has not found anything that compares to the Apple case. Have the Revenue Commissioners anything to say on that?

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)

Michael Noonan: Multinational companies structure themselves in different ways. Some of the structures are quite complex. It does not just apply to Apple. In Ireland's case, the legal advice and the opinion of Revenue was that only the profits generated from economic activity in Ireland were taxable. Apple paid the full 12.5% on the profits made on the economic activity in Ireland.

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)

Pearse Doherty: The answer is "No". So the statement made to this committee - a throwaway statement that the Commission is asking us to collect tax on Apple's worldwide profits - is false. The accurate statement is that the Commission is asking us to tax the profits that are recorded by Apple of sales that happen outside of the Americas. Would that not be a more accurate 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)

Mr. Niall Cody: It is a lesson to anybody appearing before any parliamentary committee. I know that Mr. Cook subsequently said "Sorry" and that what happened was not exactly as he had said. Apple has clarified the situation, and obviously it is appealing the case. If Apple felt that there was another story behind this, involving deals and political influence, I am sure that it would be...

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)

Seán Sherlock: ...recorded in the branch and whether, therefore, it had to be taxed in Ireland, or recorded in the stateless headquarters and, therefore, not to be taxed in Ireland. We found that the recordings by Apple, which we did not question, could not be supported by economic activity. That is why they ought to be recorded in the branch of the company that is taxable in Ireland. She went on to...

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)

Paddy Burke: The Irish authorities say that Apple was adhering to the letter of the law. If the Commission is successful in the appeal, how difficult would it be for the Irish tax authorities to collect the €13 billion from Apple? They believe they have complied with the law and the tax rulings. Would it be enforceable? Would the Irish authorities be able to enforce the collection of 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)

Michael Noonan: No. The Revenue's position was that there was nothing in any of the files, including Apple, that would give rise to the initiation of an inquiry. I do not have access. As I stated previously, these files contain data that are confidential between the companies and Revenue, but what the Commissioner said was there was nothing in this documentation that was examined by the Commission which...

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)

Pearse Doherty: ...knew about it a long time before that but did nothing about it. They did not tell us but turned a blind eye. We do not have access to the information as to where are the economic rights of Apple's intellectual property. We do not have access to their accounts. Revenue had all of that. In my view, Revenue may have known this as early as 1990 and yet as Mr. Cody rightly said, a paper was...

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)

Michael Noonan: ...to be absolutely certain of the detail in retrospect. The first opinion was in 1991, which is 26 years ago. The Senator may recall, if she has done some research into corporation tax, that Apple came to Ireland in 1980. Right through the 1980s - like other exporting companies - it had export sales relief. Export sales relief meant that exporting manufacturing companies paid zero tax....