David Cullinane (Sinn Fein) | Oireachtas source

I return to the issue of corporation tax on which we did not get satisfactory responses yesterday. It is important that we have an honest and transparent debate on this issue. When people raise concerns about corporation tax it is often met with derision from certain Members of this House but I am sure everybody would agree it is important that we have an opportunity to ask questions.

I will quote from a hearing that took place in the United States Senate on 15th of this month. The head of Apple's tax operations was before the Senate committee. He stated:

Since the early 1990s, the government of Ireland has calculated Apple's taxable income in such a way as to produce an effective rate in the low single digits. The rate has varied from year to year, but since 2003 has been 2% or less.

A written response from Apple to the same committee states:

Since the early 1990s the Government of Ireland has calculated Apple's taxable income in such a way as to produce an effective rate in the low single digits, and this is the primary factor that contributes to Apple's rate. The rate has varied from year to year but since 2003 has been 2% or less.

The chief executive officer of Apple, Mr. Tim Cook, and Apple's director of tax operations both made the same comment when questioned by the US Senate.

There appears to be an anomaly or a loophole in Irish tax law which provides that a company is tax resident where its central and control management is located but not where it is incorporated. That allows some of these multinational companies to set up two companies, one which is non-resident in Ireland - perhaps in the Cayman Islands or elsewhere - and one which is resident in Ireland. It is similar to the Apple subsidiary company which was under scrutiny by the US Senate committee. That company has only three directors in Ireland. It does not have any employees. A total of €30 billion was funnelled through this company. It did not pay any taxes in this country or in the US. That is what is happening.

The biggest threat to multinational jobs in this country is that this practice is happening and that the British Government and the American Government are now watching. There is a world of difference between Apple or any company manufacturing in this country and paying their taxes but these subsidiary companies that are being set up are clearly designed to avoid paying tax. We need to have that discussion and the Minister should be brought before the House for it.