Written answers
Tuesday, 13 December 2016
Department of Finance
Revenue Commissioners
Michael McGrath (Cork South Central, Fianna Fail)
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156. To ask the Minister for Finance if the Revenue Commissioners have launched a review of tax opinions issued to multinationals; the number of tax opinions which have been provided to the European Commission's state aid directorate in recent years; the period covered by those opinions; and if he will make a statement on the matter. [39527/16]
Michael Noonan (Limerick City, Fine Gael)
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I am informed by Revenue that Revenue has updated its guidance to confirm that opinions issued to taxpayers, whether multinational companies or other taxpayers, will remain valid for a maximum period of five years. If a taxpayer wishes for a confirmation to continue after that time, an application for a renewal or extension must be made. It has always been the case that an opinion will only remain valid for so long as the facts and circumstances on which it is based continue to exist and the relevant legislation and practice remains in place.
Revenue has confirmed that it has begun reviewing a number of opinions that were provided more than five years ago.
In response to a request for information from the European Commission, in the context of its State Aid enquiries into ruling practices in different Member States, Ireland provided the Commission with details of opinions provided to over 300 companies, including all opinions issued in the years 2010, 2011 and 2012 on a range of issues.
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