Paul Murphy (Dublin South West, Socialist Party)
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125. To ask the Minister for Finance his plans to publish the details of the number of tax opinions provided by the Revenue Commissioners, including the amount provided to multinational corporations and those based outside the State; and if he will make a statement on the matter. [24574/15]

Michael Noonan (Limerick City, Fine Gael)
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I am advised by the Revenue Commissioners that, as statistics are not currently compiled on the number of tax opinions issued by Revenue each year, they are not in a position to publish details of the number of such opinions or the number provided to multinational companies and companies based outside the State.

In providing an opinion on the tax implications of a particular transaction or situation of a taxpayer, Revenue's role is to interpret and apply the tax law correctly so that taxpayers can comply with their obligations under the law.

Revenue tries to minimise the need for taxpayers to require opinions by making a wide range of taxation information available on the Revenue website. Accordingly, the circumstances in which a taxpayer should require an opinion are relatively limited. Revenue will issue an opinion where the issues are complex, information is not readily available or there is genuine uncertainty in regard to the applicable rules under the relevant tax law.

Statistics are not compiled on the total number of opinions issued by Revenue. However, in responding to the European Commission's State aid enquiries in relation to tax ruling practice in EU Member States, Revenue identified that in the period 2010 to 2012 the number of advance opinions issued to companies on matters relating to corporation tax was as follows:

Opinions on corporation tax will typically deal with issues such as company restructurings, classification of activities as trading, deductible expenditure, capital allowances and application of tax reliefs (e.g. loss relief).

In the light of the discussions currently taking place at EU Council on the Commission's proposal to amend the Council Directive on administrative cooperation to provide for automatic exchange of information on cross-border tax rulings, Revenue will be reviewing its procedures for recording and collating tax opinions that are issued to companies, with a view to fully implementing the requirements of the Directive as and when adopted by the Council. I am advised by the Revenue Commissioners that they will consider the question of publishing data on the number of such opinions within this context.