Pearse Doherty (Donegal South West, Sinn Fein)
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178. To ask the Minister for Finance further to sworn statements given by Apple representatives to the U.S. Senate Committee investigating the company's tax matters, if he can explain the way Apple's taxable income in the State is calculated in such a was as to bring its corporation tax to single digits; and if these methods are applied to other multi national corporations [25525/13]

Michael Noonan (Limerick City, Fine Gael)
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I cannot comment on the tax affairs of individual companies. However, I am aware of the Memorandum issued by the US Senate Permanent Subcommittee on Investigations last week. I want to make it clear that we do not have a special low corporation tax rate for individual companies. Ireland’s tax system is statute-based so there is no possibility of individual special tax rates for companies.

All companies resident in Ireland are chargeable to corporation tax at the 12.5% rate on the profits that are generated from their trading activities in Ireland. A higher 25% rate applies in respect of investment, rental and other non-trading profits. Chargeable capital gains are taxable at the capital gains tax rate of 33%. The tax rates being quoted publicly this week are emphatically not the rate of tax paid by such companies - or by any company on its Irish activities. Having examined the document produced by the US Senate Subcommittee, it appears that the rate that is being quoted is got as follows: the tax charged in Ireland on the branch activities in Ireland of companies that are not resident here is divided by the entire profit of the companies concerned as if they were resident here, which they are not.

It is clearly wrong and misleading to attribute this rate of tax to Ireland. Companies which are not tax-resident in Ireland are no more chargeable in Ireland in respect of their entire profits than they are in any other country in which the company is not tax resident - and these company profit figures should not be used to assert special tax rates that simply do not apply here.

Pearse Doherty (Donegal South West, Sinn Fein)
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179. To ask the Minister for Finance the average statutory and effective tax rate for multi national corporations in the 1980s, 1990s and the 2000s. [25526/13]

Michael Noonan (Limerick City, Fine Gael)
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I am informed by the Revenue Commissioners that the statutory standard Corporation tax rates for all companies is as shown in the following table for all years from 1980. Information in relation to the tax payments of multinational corporations is not separately identifiable. In relation to the effective tax rate for multinational corporations, I have repeatedly stated that there is no agreed international methodology for calculating the ‘effective rate’ of corporation tax. As there is no single internationally agreed comparative measure in place, I am not in a position to provide such a measure for the period referred to by the Deputy.

You may wish to note that information from the corporation tax returns filed by all companies for tax years from 1990/91 up to 2010, the latest year currently available, is published in the Statistical Reports of the Revenue Commissioners. The information in the reports for tax years 1995/96 and onwards is available on the Revenue Commissioners website and can be accessed using the following link http://www.revenue.ie/en/about/publications/statistical-reports.html.

Based on the information in the Revenue reports, the following table shows the standard rate of Corporation Tax applicable to profits earned in the year, with the following notes:

- Where two tax rates are shown for a year it denotes a rate change applying during the year.

- The Corporation tax for years prior to 2001 includes an element of income tax paid by companies.

- In addition to these rates, a rate of 25% applies to non-trading income such as Schedule D Case III, IV and V, certain land dealing activities and income from working minerals and petroleum activities with effect from 1 January 2001

Further, it should be noted that there were a number of tax incentives that were generally available to all companies in the 1980s. I would refer the Deputy to the scheme of relief from corporation tax provided for in Part IV of the Corporation Tax Act, 1976 (Export Sales Relief) which expired on 5 April 1990. That relief provided for a reduction to nil of the corporation tax on profits from the export of goods manufactured in the State.

Export Sales Relief was withdrawn on a phased basis from 1980 to 1991 and was effectively replaced with a relief provided for in Chapter VI of the 1980 Finance Act (Manufacturing Relief), which provided for a reduction of the corporation tax to a rate of 10% on profits from the sale of goods manufactured in the State. Manufacturing Relief expired on 31st December 2010. The manufacturing scheme of relief was extended to activities carried out in the IFSC and ancillary services located in the Customs House Docks Area and to activities carried on in the Shannon Airport Area. Relief for these activities expired on 31 December 2005.