Sir, – The outcome of European Commission investigations into sweetheart tax deals for multinational companies, including Apple in Ireland, is of real importance at a time when tax competition between states is increasing and the momentum is towards multinationals paying next to no tax ("Ireland's sweetheart tax deals under threat as EU investigates", July 14th).
While Revenue states that it offers companies “advisory opinions” and not binding tax rulings, the net effect is the same. It is the detail of these opinions and the corporations to which they are issued, together with the scale of taxes foregone that they give rise to, that is a vital matter of corporate tax transparency and fairness.
Key to the whole issue is the definition of taxable income and Revenue’s opinion as to how it will treat the company’s depiction of that.
This is especially the case for a multinational corporation such as Apple, where the level of taxable income in Ireland depends on convoluted intra-company transactions and the treatment of payments by one Apple subsidiary for the use of intellectual property owned by another.
Citing reasons of taxpayer confidentiality, Revenue does not publish the details or nature of its “advisory opinions”, or the basis for them. But neither does it publish (even in anonymised versions) any summary of the decision types, the category, scale or sector of companies involved, or the tax effect of particular decision or company types.
Regarding the European Commission’s investigation of the arrangement with Apple, it is time we knew what sweetheart tax deals, if any, have been done in our name.
More generally, Debt and Development Coalition Ireland urges that Revenue should publish annually the number, nature and taxable income effect of its advance opinions, at least in aggregate form; seek powers to inquire into transfer pricing transactions within multinationals that boost Irish profits (as well as those that deplete them); and maintain vigilance on companies operating in Ireland but without a large economic presence, particularly those with large intra-group transfers. – Yours, etc,
ÉAMONN CASEY,
Policy and Outreach Officer,
Debt and Development
Coalition Ireland,
North King Street,
Dublin 7.