Pearse Doherty (Donegal, Sinn Fein)
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105. To ask the Minister for Finance the steps he has taken to implement the action points recommended by the OECD under the BEPs initiative; and if he will make a statement on the matter. [34126/16]

Michael Noonan (Limerick City, Fine Gael)
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Ireland has been a keen supporter of the OECD BEPS process and has been actively engaged in the implementation of the BEPS recommendations since the reports were published in October 2015. I recently published an Update on Ireland's International Tax Strategy which sets out what we have done and what we plan to do regarding the implementation of the OECD BEPS recommendations. In respect of the 15 BEPS reports:

- BEPS Actions 2, 3 and 4 put forward recommendations that have been legislated for in the EU Anti-Tax Avoidance Directive. The Directive will therefore see three of the key OECD BEPS recommendations implemented consistently across Europe. These are rules targeting hybrid mismatches, interest deductibility rules and Controlled Foreign Company rules. Ireland will implement these changes in line with agreed deadlines set out in the Directive.

- Action 5 developed the modified nexus approach for IP regimes. Ireland's Knowledge Development Box was introduced in line with this approach. The Knowledge Development Box was reviewed by the OECD's Forum on Harmful Tax Practice and was declared to be the first such incentive to be fully compliant with the modified nexus rules agreed in BEPS Action 5.

- Action 5 also makes recommendations on exchange of information. Ireland is implementing the exchange of information requirements fully  in respect of tax rulings set out in this report.

- Actions 6, 7 and 14 make a series recommendations for updating tax treaties to prevent tax treaty shopping and improve dispute resolution. The BEPS multilateral instrument (MLI) will ensure that tax treaties are updated to reflect these BEPS recommendations. The MLI is close to being agreed at the OECD. Ireland has played an active part in this work.

- Actions 8 to 10 provide recommendations on transfer pricing. In May this year, new transfer pricing rules were agreed at the OECD. As set out in the recent update on Irreland's international tax strategy we are now considering what changes are required to ensure that Ireland's transfer pricing rules meet the standards set in the OECD transfer pricing guidelines.

- Action 12 recommends the introduction of mandatory disclosure rules for promoters of tax schemes. Ireland is one of the few countries to already have mandatory disclosure rules in our domestic legislation.

- Action 13 recommends countries introduce country-by-country reporting. Ireland legislated for country-by-country reporting in Finance Act 2015 and signed a Multilateral Competent Authority Agreement in January 2016 to share these reports with other tax authorities

- The remaining BEPS reports, Actions 1, 11 and 15, do not make any specific recommendations. Further work continues on the areas examined by these reports in various OECD working parties and Ireland is actively engaging in this work.  

Ireland will continue to take actions needed to implement the BEPS reports. The review of Ireland s corporation tax code, which has been launched with Budget 2017, will include consideration of what further actions Ireland may need to take to ensure we are fully compliant with the OECD BEPS recommendations.