Paul Murphy (Dublin South West, Socialist Party)
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230. To ask the Minister for Finance if he will provide, in tabular form, the number of certificates for non-deduction of withholding tax issued for each of the past five years for accounts in the following states: the Netherlands Antilles, Jersey, Guernsey, Isle of Man, British Virgin Islands, Turks and Caicos Islands, Andorra, Liechtenstein, Monaco, San Marino and Switzerland. [24573/15]

Michael Noonan (Limerick City, Fine Gael)
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I am informed by the Revenue Commissioners that the purpose of the EU Savings Directive is to ensure that individuals resident in an EU member state who receive interest income from another Member State are taxed in the Member State in which they are resident for tax purposes.  To this end, payments of interest are either (1) reportable by paying agents in the EU to the tax authorities in the home member state of the paying agent or (2) subject to withholding tax in those member states which opted to apply withholding tax rather than report the payment.

Most of the EU member states opted to exchange information regarding the interest payments made by paying agents in their jurisdiction to individuals resident in another member state.  Initially, Austria, Belgium and Luxembourg opted to apply the withholding tax instead of exchanging information.  Some associated and dependent territories, namely, Netherlands Antilles, Jersey, Guernsey, Isle of Man, British Virgin Islands and Turks and Caicos Islands and certain third countries, namely, Andorra, Liechtenstein, Monaco, San Marino and Switzerland also entered into agreements with the EU to apply a withholding tax.  In this regard, the Savings Directive and the related agreements provided for a procedure to allow recipients of interest, who would otherwise receive interest payments under deduction of withholding tax from these countries and territories listed above, to apply to their own tax authority for a certificate for non-deduction of withholding tax. The application would be made on the basis that the interest income concerned is being returned to the beneficial recipient's tax authority and is being fully taxed.

I am informed by the Revenue Commissioners that the information requested by the Deputy is not recorded on Revenue's systems. However there is no record that any non-deduction certificates have been issued by Large Cases Division, which deals with high net worth individuals, for an account in the jurisdictions listed by the Deputy. While the Commissioners consider it unlikely that such certificates were issued by other Revenue Divisions, they will check in that regard and correspond directly with the Deputy.