Written answers

Tuesday, 29 November 2011

9:00 pm

Photo of Clare DalyClare Daly (Dublin North, Socialist Party)
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Question 93: To ask the Minister for Finance if he will consider allowing, as a minimum, that moneys paid in order to prove the existence of heave-inducing pyrite by householders, which can amount to €3,000 to €4,000 per home, would be offset against the residents' tax liability, in view of the fact that they are the victims of this crisis. [37519/11]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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As the Deputy will appreciate, I receive numerous requests for the introduction of new tax reliefs and extensions to existing ones. The Deputy will also appreciate that I must be mindful of the public finances and the many demands on the Exchequer. Tax reliefs, no matter how worthwhile in themselves, reduce the tax base and make general reform of the tax system that much more difficult. I have no plan to introduce further tax reliefs on the lines you suggest.

Photo of Robert DowdsRobert Dowds (Dublin Mid West, Labour)
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Question 94: To ask the Minister for Finance the expenditure by multinational groups in respect of their operations outside Ireland which are considered bona fide for the purposes of calculating their tax liability here; and if this includes expenditure on services which were being carried out by the multinational here at an earlier stage. [37546/11]

Photo of Robert DowdsRobert Dowds (Dublin Mid West, Labour)
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Question 130: To ask the Minister for Finance the checks that are carried out on the tax reduction expenditure declared by multinational companies to ensure that each item is legitimate bona fide expenditure which reduces profits made in Ireland. [37548/11]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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I propose to take Questions Nos. 94 and 130 together.

A multinational company that is resident in Ireland is subject to tax on all profits of the company wherever arising. To the extent that those profits arise from trading activities, they are taxed at 12.5%. The profits of a company for tax purposes are the profits computed in accordance with standard accounting practice as adjusted by statute.

Where in the course of its trade a company purchases goods, services or licensing rights from another company the cost of such goods, services or rights is deductible in computing profits for tax purposes. Where these purchases are made with a group of companies they are subject to the normal arm's length pricing rules. The amounts deductible are in respect of real purchases. It is, of course, possible that goods and services that are not currently sourced in Ireland were previously sourced here.

I am informed by the Revenue Commissioners that the largest multinationals are dealt with in Revenue's Large Cases Division. That Division closely monitors all companies within its remit. Companies are obliged to file their returns in accordance with the self-assessment provisions and the Large Cases Division runs a compliance programme to follow up companies who fail to meet their filing obligations. Tax returns, tax computations and accounts are assessed in accordance with the Division's risk assessment programme. Interventions in the form of enquiry or audit are made where significant areas of risk of non-compliance are identified during this process. The risk analysis takes into account the scale of a company's operations as well as the complexity involved. Tax reduction expenditure falls within this risk assessment process. Large Cases Division aims to ensure that all significant potential non-compliance is challenged and to keep advancing its effectiveness in this area.

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