Pearse Doherty (Donegal, Sinn Fein)
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124. To ask the Minister for Finance if companies can make disclosures that are classified as unprompted even after Revenue has requested for a self-review of tax compliance effectively alerting the company to revenues awareness and interest in a specific tax practice; and if he will make a statement on the matter. [5116/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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I am advised by Revenue that its Compliance Intervention Framework, which is in place since May 2022, provides for a consistent, graduated response to compliance risks and taxpayer behaviour. This response ranges from extensive opportunities for taxpayers to self-review and correct any aspect of their tax compliance (Revenue’s preferred option) up to investigation with a view to criminal prosecution in the most egregious cases.

I am further advised that the Framework provides for three distinct levels of intervention:

1. At Level 1, a formal Revenue enquiry has not commenced and a taxpayer still has the opportunity to make an “Unprompted” disclosure of any tax default, thereby minimising penalties and avoiding the risk of publication in the quarterly list of defaulters.
2. At Level 2 a taxpayer may still make a “Prompted” disclosure and avail of significant mitigation of penalty and avoid publication.
3. At Level 3, no disclosure opportunity is available, but a taxpayer may still avail of some mitigation of penalty by cooperating fully with a Revenue investigation.

Pearse Doherty (Donegal, Sinn Fein)
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125. To ask the Minister for Finance if he intends to commission an independent assessment of the impacts of his tax policies on the economies of developing countries, as recommended by the UN Committee on Economic, Social and Cultural Rights; and if he will make a statement on the matter. [5155/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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As the Deputy will be aware the Department of Finance published an independent economic analysis into the possible effects of the Irish tax system on developing economies in 2015. The analysis, completed by the IBFD on behalf of the Department, was entitled ''Spillover Analysis Possible Effects of the Irish Tax System on Developing Economies' and included a baseline analysis of Ireland's tax treaty network, tax system, and trade and capital flows with developing countries.

On foot of the publication of the report, the Government took a number of steps to address issues raised including completing the renegotiation of two specific tax treaties, and using the analysis to inform Ireland's future interactions with developing countries.

This research has also directly fed into the formulation of Ireland's Treaty Policy Statement which was published in June 2022 following a public consultation process and bilateral engagements with a broad range of stakeholders, including NGOs. A key element of the treaty policy statement was to directly addresses treaty policy approaches with developing countries. The statement contains an explicit commitment to not approach any least developing country, as defined by the UN, in relation to opening discussions on treaties, and where Ireland is approached a commitment is made to carry out a spillover analysis to ensure that benefits are likely to accrue prior to agreeing to any such treaty. Furthermore Ireland will also fully consider the preferences of the partner country regarding source taxation in those negotiations.

Given the previous review and the on-going specific actions developed in the Treaty Policy Statement there are currently no plans to conduct another such analysis at this time.

Ireland continues to take action to ensure the Irish tax code is in line with new and emerging international tax standards as agreed globally. This includes through our work at OECD and at the UN where Ireland is also actively participating in negotiations on the UN Framework Convention on International Tax Cooperation and has supported the election of an Irish expert to the UN Tax Expert Committee.

It is also important to acknowledge the reforms we have undertaken and the positive role we continue to play at OECD and EU, and that today we have far more robust international tax rules and safeguards to prevent abuse, arbitrage, base erosion, and profit shifting than existed a decade ago. We are fully compliant with the OECD standards of transparency and exchange of information in relation to tax matters and are at the forefront in implementing the agreed OECD ‘Pillar two’ minimum effective rate of taxation of 15%, and we remain deeply engaged in the ongoing work to finalise the OECD International Tax Agreement.