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Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Use of Section 110 by Russian Firms: Dr. Jim Stewart (1 Jun 2022): Pearse Doherty: ...number of questions that I am interested in have already been asked. I have a question about the issue of tax residency. We know the challenges in defining tax residency, where they arose in the Apple case and the so-called stateless income tax strategy that was in operation at that time. Some argue that the tests of tax residency in Ireland, namely, the central management and the...
Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: Use of Section 110 by Russian Firms: Dr. Jim Stewart (1 Jun 2022): ...and we can bolster this by where meetings of directors take place. I do not have the solution to this. It is an area of corporate tax planning that is very widely used. It featured in the Apple case, as we saw, and will feature in other cases as well.

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