Written answers

Wednesday, 5 November 2014

Department of Finance

Corporation Tax Regime

Photo of Richard Boyd BarrettRichard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance)
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40. To ask the Minister for Finance if he will confirm reports that he is working with US multinationals to design the new knowledge box corporation tax scheme; and if he will make a statement on the matter. [41766/14]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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In last month's Budget I announced several changes to Ireland's corporation tax regime, as part of an overall strategy to "play fair and play to win".  This included a change to Ireland's rules on company tax residence which will bring our company residence rules into line with those in the rest of the OECD and an end to the so-called 'Double Irish'.  This was balanced with a number of competitive enhancements which were contained in the "Road Map for Ireland's Tax Competitiveness". 

This strategy was underpinned by extensive research undertaken and commissioned by my Department over the course of 2014 which has now been published.

One of the key findings of the research is that the FDI sector is very important for economic growth and employment in Ireland and that Ireland needs a competitive corporate tax offering to attract FDI.  In particular, we need to ensure a competitive offering for knowledge-based investment which is related to research and development and intellectual property.

In recognition of the fact that investment and growth in OECD economies is increasingly driven by investment in intangible assets, putting in place an attractive intellectual property offering is key for Ireland's success in attracting FDI.  This is why I made a clear statement of my intention to introduce a competitive income-based regime for intangible assets in Ireland which will be called a "Knowledge Development Box" or "KDB".

I view this as a positive measure for Ireland and my intention is that the Irish KDB will be among the best in class on offer internationally.  In order to gather views from as broad a spectrum as possible on what this may entail, I will launch a public consultation process before the end of this year on how the Irish KDB should operate. 

As is the case with all public consultations that have been undertaken by my Department on corporation tax, input has been welcomed from all sections of society.  A number of parties came forward to give their views on the public consultation on the OECD Base Erosion and Profit Shifting ('BEPS') Project from earlier this year, including groups who represent multinationals who are based in Ireland, political parties, Non-Governmental Organisations and individual citizens.  I expect the consultation on the KDB will be no different, and I would encourage all interested parties to input to this process.

It is intended that the design of the KDB in Ireland will be along the lines of what are commonly known as 'patent boxes' which have existed for many years in countries that compete with us for FDI.  At present, the measures that are in place in our competitor jurisdictions are the subject of on-going discussions at the OECD and EU level, as regards to their compatibility with the international rules around fair tax competition.  As I said in my Budget announcement, it will be necessary to ensure that the Irish KDB meets with the standards that remain to be agreed by both the OECD and the EU.

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