Micheál Martin (Cork South Central, Fianna Fail)
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229. To ask the Minister for Finance the progress being made on the international talks on double taxation; and if he will make a statement on the matter. [4834/14]

Michael Noonan (Limerick City, Fine Gael)
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The most prominent issue in international tax at the moment is the OECD Base Erosion and Profit Shifting project or BEPS, to which I believe the Deputy is referring. Ireland has welcomed both the OECD BEPS report of February 2013 which identified the problems of Base Erosion and Profit Shifting, and the subsequent BEPS Action Plan published in July 2013, which outlined 15 actions to be taken to deal with the problems identified in the report. The plan is essentially a roadmap, with a timetable for completion of actions varying from September 2014 to December 2015.

As a result of this work, the OECD may change its international tax guidelines and make recommendations regarding mismatches which exist between different countries' rules, which countries would have to strongly consider implementing in their national legislation or tax code. In addition preparatory work is under way on a multilateral instrument to which countries will be expected to sign up which will implement certain measures on a multilateral basis. 

The Government published Ireland's International Tax Strategy as part of Budget 2014.  It includes an International Tax Charter which sets out Ireland's policy objectives and commitments on a range of international tax issues. The Finance (No 2) Act 2013 ensured that, in relation to our tax treaty partners, a company cannot be 'stateless' in terms of its place of tax residence. The "stateless" company change will not by itself bring an end to international tax planning. That would require concerted multilateral action by many countries acting together. World leaders (G8, G20) have already acknowledged that a global, co-ordinated approach was needed. The OECD is leading this concerted international initiative through its BEPS project. Ireland is an active participant in this process.