Pearse Doherty (Donegal South West, Sinn Fein)
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182. To ask the Minister for Finance the tax returned to the Vodafone group; if so, the reason and the cost to the State; and if he will provide any other companies which operate internationally to which the Government has returned tax in the past three years. [37403/13]

Michael Noonan (Limerick City, Fine Gael)
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I am informed by the Revenue Commissioners for reasons of taxpayer confidentiality that they are unable to comment on the circumstances relating to an individual taxpayer. However, in general, bilateral double taxation agreements allocate taxing rights between two countries in order to ensure that income is not subject to double taxation. Tax treaties generally contain a mutual agreement procedure which provides for tax authorities to agree a consistent approach with each other in relation to tax disputes such that a taxpayer does not end up with State A and State B taxing the same income twice. This can result in the reallocation of tax between countries resulting in refunds by one country and additional payments to the other.