Pearse Doherty (Donegal, Sinn Fein)
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165. To ask the Minister for Finance the number of transactions that have been reported to the Revenue Commissioners by obliged promoters since the introduction of the Mandatory Disclosure of Certain Transactions Regulation 2011; and the type of entities from which the reports were received, the form of transaction reported and the criteria under which the reporting was triggered per annum. [39337/17]

Paschal Donohoe (Dublin Central, Fine Gael)
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1. Number of Transactions Reported to Revenue

Revenue has received eleven disclosures from promoters of tax schemes under the Mandatory Disclosure regime.

Subsequent to receipt of the disclosures, Revenue received from the promoters associated client lists containing the names of 494 taxpayers. While a taxpayer may be listed on a client list this, in itself, is not evidence that the taxpayer actually participated in and implemented the tax scheme disclosed. In the case of each individual listed an enquiry has to be carried out to determine if, and to what extent, the scheme was implemented by the individual concerned.

2. Types of Entity

The disclosures have been received from the following types of entity:

- Large General Accountancy and Tax Firms (4)

- Specialist Tax Advisory Practices (4)

- Financial / Wealth Management Practices (2)

- Corporate Trustee (1)

3. Form of Transaction Reported and Criteria Under which the Transaction was Reported (per annum)

Eleven schemes have been disclosed under the mandatory disclosure regime. Four relate to employee benefit trusts (these are arrangements designed to deliver tax-free benefits to employees). Three relate to various artificial loss schemes. Two relate to share transactions. The remaining two schemes relate to assets and liabilities of a partnership transferred to a limited company (in these cases the transaction described was found to be in order).

All disclosures have been examined and, where appropriate, enquiries have been opened in respect of those who have been identified as participants in the schemes. In addition, where appropriate, Revenue has recommended amendments to the legislation being exploited.