Joan Burton (Dublin West, Labour)
Link to this: Individually | In context | Oireachtas source

60. To ask the Minister for Finance if he will provide statistical information (details supplied) in respect of each of the years 2010 to 2018 and from 1 January 2019 to date. [39065/19]

Joan Burton (Dublin West, Labour)
Link to this: Individually | In context | Oireachtas source

61. To ask the Minister for Finance the number of correlative adjustments received by the country in which the tax settlement giving rise to the adjustment has been agreed in each of the years 2010 to 2018 and from 1 January to date in 2019, in tabular form. [39066/19]

Joan Burton (Dublin West, Labour)
Link to this: Individually | In context | Oireachtas source

62. To ask the Minister for Finance the number of protective claims for correlative adjustments received for claims that may arise in the future together with an estimate of the tax involved in each of the years 2012 to 2018 and from 1 January to date in 2019, in tabular form. [39067/19]

Joan Burton (Dublin West, Labour)
Link to this: Individually | In context | Oireachtas source

63. To ask the Minister for Finance the estimated number of correlative adjustments expected to be received in 2019 and 2020 in the work plans of the Revenue Commissioners. [39068/19]

Paschal Donohoe (Dublin Central, Fine Gael)
Link to this: Individually | In context | Oireachtas source

I propose to take Questions Nos. 60 to 63, inclusive, together.

I am advised by Revenue that as at 30 June 2019, the latest date for which such data has been collated, approximately €191 million in tax is the subject of open correlative relief claims.

Table 1 includes the number of correlative relief claims made by companies for each of the years 2010 to 2019 (up to 30 June 2019), together with the number of claims where correlative relief was granted, and the tax value of relief granted.

Table 1

* Correlative 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.

Table 2 includes details on the number of open correlative relief claims made by companies for each of the years 2010 to 2019 (up to 30 June 2019), including the quantum of adjustments claimed by these companies and the tax value of relief requested in each year.

Table 2

Table 3 provides a further detailed breakdown of closed correlative relief cases in respect of claims received after 1 January 2014 which were either granted or withdrawn (full details of correlative relief claimed are not available for the years 2010 to 2013):

Table 3

* Correlative 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.

Table 4 provides an analysis of the correlative relief claims received by country of adjustment since 1 January 2014 (full details of correlative relief claimed are not available for years 2010 to 2013

Table 4

A correlative relief claim can arise where an overseas tax authority imposes a transfer pricing adjustment on one party to an intercompany transaction and taxes profits that have already been taxed in Ireland. In order to avoid double taxation, the Irish party to the transaction may have the option to approach Revenue for a repayment of tax on a unilateral basis under the provisions of a double taxation treaty (that is, without involvement of the overseas tax authority). Given the nature of correlative relief claims, Revenue has advised that it is not possible to provide an estimate of claims which may arise in the future. Revenue will only consider the merits of a claim for correlative adjustment when all the necessary information and documentation required to be submitted with a request for a correlative adjustment is provided.

Finally, the Deputy should note that claim numbers and amount of tax relief granted as a result of corresponding adjustments agreed between Revenue and tax authorities of other countries under the Mutual Agreement Procedures (MAP) provided for in Double Tax Treaties are not included in the above figures.