Joan Burton (Dublin West, Labour)
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96. To ask the Minister for Finance further to Questions Nos. 123 to 125, inclusive, of 17 October 2017, the analysis of cases settled by way of mutual agreement procedures, MAPs; the year and the amount of tax involved; the number of settlements open under MAPs; the tax potentially at risk; and if he will make a statement on the matter. [47306/17]

Joan Burton (Dublin West, Labour)
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97. To ask the Minister for Finance the number of advance pricing arrangements the Revenue Commissioners have agreed and which are currently in place, by country; the number of companies involved; and if he will make a statement on the matter. [47307/17]

Paschal Donohoe (Dublin Central, Fine Gael)
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I propose to take Questions Nos. 96 and 97 together.

I am informed by Revenue that there are currently 29 open Mutual Agreement Procedure (“MAP”) cases. These relate to adjustments raised by tax authorities in Tax Treaty partner countries in respect of transfer-pricing or the attribution of profits to permanent establishments. Some of these cases are at an early stage and Revenue has not yet received sufficient information to estimate the potential Irish tax relief that could result from closing the cases. For those cases where the potential relief is known, the maximum aggregate tax value of the relief could amount to €243m. However, while this aggregate value is based on granting relief for the full foreign adjustments, the total relief ultimately granted is likely to be less, as a result of the withdrawal or reduction of the foreign adjustments concerned on the conclusion of the MAP negotiations.

The following table includes the number of MAP requests made by companies for each of the years 2008 to 2016 and to date in 2017, together with the number of requests where tax relief was granted and the tax value of the relief involved:

* Relief may be granted over a number of years and may take the form of increasing losses to be carried forward as well as refunds and off-sets.

** As there is only one case involved, publication of the amount of tax relief granted is not considered appropriate as it could lead to identification of the company.

With respect to Question No. 47307/17, a bilateral Advance Pricing Arrangement, referred to as a bilateral APA, is a binding agreement between two tax administrations, which is entered into by reference to the relevant Double Taxation Agreement. A bilateral APA governs the treatment for tax purposes of future transactions between associated taxpayers for a fixed period, generally 3 to 5 years.

I am informed by Revenue that there are 4 APAs currently in place with other countries. The APAs relate to 4 separate Irish companies. To observe taxpayer confidentiality, the OECD approach when reporting statistics is not to identify individual countries where there is a small number of agreements with those countries. The four current APAs have been agreed by Revenue with the tax administrations of two OECD countries and there are two agreements with each of these countries.