Pearse Doherty (Donegal South West, Sinn Fein)
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80. To ask the Minister for Finance the amount that could be raised for the Exchequer if corporation tax was applied to dividends received by one Irish resident company from another Irish resident company. [26069/13]

Michael Noonan (Limerick City, Fine Gael)
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Section 129 of the Taxes Consolidation Act 1997 provides that corporation tax is not charged on dividends received by an Irish resident company from another Irish resident company. The reason for this is that such dividends are paid out of profits of the paying company which have already been subject to corporation tax and to apply a corporation tax charge on the company receiving the dividends would, in effect, amount to double taxation. If an Irish resident company were to be made chargeable to corporation tax on dividends it received from other companies resident in the State, it would be necessary to provide a credit for corporation tax paid by the paying company on profits out of which the dividends are paid. As such a credit would offset the corporation tax payable on dividends received, there would be no net gain to the Exchequer from the removal of this exemption.

Pearse Doherty (Donegal South West, Sinn Fein)
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82. To ask the Minister for Finance the estimated loss to the Exchequer from the corporation tax exemption from capital gains on gains arising on the disposal of substantial shareholdings where the Irish parented group is engaged in trading activities and the subsidiary is resident in an EU Member State or a tax treaty country. [26071/13]

Michael Noonan (Limerick City, Fine Gael)
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Gains and losses arising from disposals of certain shareholdings are disregarded for tax purposes, provided that the conditions applying to the relief are fully satisfied. The exemption was introduced in 2004, and is contained in S626B TCA 1997. The purpose of its introduction was to encourage the establishment of regional headquarters and holding companies in Ireland. Most other EU Member States have similar provisions and the EU Commission approved the measure from a State aid perspective. Disposals coming within the scope of the relief are ignored for tax purposes, while losses on disposals are not available for set-off. I am advised by the Revenue Commissioners that, as there is no requirement to make a claim, it is not possible to provide the Deputy with the information requested.