Micheál Martin (Cork South Central, Fianna Fail)
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28. To ask the Minister for Finance the position regarding the "double Irish" regime; and if he will make a statement on the matter. [37645/14]

Michael Noonan (Limerick City, Fine Gael)
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I announced on Budget Day, 14 October 2014, that the Finance Bill will amend Ireland's company tax residence rules to  provide that all companies that are incorporated in Ireland will be automatically tax resident here.

The change will come into effect for new companies from 1 January 2015 while a transition period will apply until the end of 2020 for existing companies.

This change will bring Ireland's rules into line with the rest of the OECD jurisdictions and should address the reputational damage arising from the use of corporate structures commonly referred to as the 'Double Irish'.

I have always been clear that the 'Double Irish' is not part of the Irish tax offering.  It is just one example of the many international tax-planning arrangements which have been designed and developed by tax and legal advisers to take advantage of mismatches between the tax rules in two or more countries.

However, the reality is that Ireland's company tax residence rules have not kept pace with international developments and being associated with the 'Double Irish' is damaging Ireland's reputation.

In essence, the residence rules that previously existed meant that companies that were not tax resident in Ireland could be presented as Irish because they were incorporated here.  This Finance Bill amendment will mean that it is no longer possible for a company to use an Irish label of incorporation without also being tax resident here.

Removing the element of the structure which gives it the 'Double Irish' name should help restore our international reputation in the context of current EU and OECD initiatives to combat aggressive tax planning.

It is not claimed that this change will bring an end to international tax planning.  For that to happen, co-ordinated action by many countries working together will be required.  Ireland will continue to be constructively engaged on this issue at the EU and OECD initiatives and we look forward to moving forward with other countries.