Written answers

Thursday, 1 June 2017

Department of Finance

Revenue Commissioners Reports

Photo of Michael McGrathMichael McGrath (Cork South Central, Fianna Fail)
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76. 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. [26435/17]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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I am informed by Revenue that it is their policy that all opinions issued to taxpayers, including multinational companies and other taxpayers, have a maximum validity period of 5 years.  Giving effect to this policy, Revenue published guidance in January of this year (eBrief No. 8 of 2017) confirming that any opinion issued more than 5 years ago, and on which a taxpayer wishes to continue to rely, is subject to review.

A taxpayer who wishes to rely on an opinion issued before 1 January 2012, in respect of any transaction, period or part of a period after 1 January 2017, has until 30 June 2017 to make an application to Revenue for the renewal or extension of the opinion.  The application must be made to the taxpayer’s local tax district and must comply with the requirements set out in Revenue’s published guidelines on obtaining an opinion.  The guidelines are available on the Revenue website () and are contained in Tax and Duty Manual 37.00.40 for cases dealt with by Revenue’s Large Cases Division and in for cases submitted for opinion through the Revenue Technical Service.

In response to requests for information from the European Commission, in the context of its State Aid enquiries into ruling practices in different Member States, Ireland has provided the Commission with details of over 500 opinions given to companies, most of which were issued in the years 2010-2013 and addressed the application of direct tax legislation to the companies concerned for those, or subsequent, years.


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