Written answers

Friday, 16 September 2016

Department of Finance

Revenue Commissioners Enforcement Activity

Photo of Clare DalyClare Daly (Dublin Fingal, Independent)
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299. To ask the Minister for Finance the number of Revenue Commissioners opinions or rulings similar to those offered to a company (details supplied) which have been made by the Revenue Commissioners, including the sectors and years involved and the details of the issues concerned. [25664/16]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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It is in the public domain that the opinions granted to Apple related to the attribution of profits to the Irish branches of non-resident companies.

As part of the Apple State Aid investigation, the European Commission was given over 300 non-binding opinions that were issued by Ireland.  These covered a number of circumstances, sectors and periods of time.

On average, the Revenue Commissioners only issue around 100 such opinions per year.  In contrast, some countries give thousands of such rulings per year.  Commissioner Vestager has acknowledged that opinions or rulings are not a common feature of the Irish tax system.

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