Other Questions

Corporation Tax

Pearse Doherty

Question:

8. Deputy Pearse Doherty asked the Minister for Finance if the billions of euro of intangible assets onshored during the period when there was no limit on the ability of companies to use these assets to write off tax liabilities will be taxed going forward; and if he will make a statement on the matter. [21436/18]

In 2015, the Minister's predecessor made a bizarre move when he decided to allow that 100% of the intangible assets of a company could be written off against profits. The result was a massive onshoring of intangible assets. It effectively cancelled out billions of euro of profits for tax purposes. There is no reason this huge mistake cannot be rectified. We know from Mr. Seamus Coffey that the benefit to the State of doing that would be €750 million per year. Is this under consideration in advance of budget 2019?

In the Finance Bill 2017, I introduced an 80% cap on the relevant income against which capital allowances for intangible assets may be deducted in a tax year.  This reinstated the cap which had been in place but which was lifted in the Finance Bill 2014 and therefore did not apply to assets onshored between 1 January 2015 and 10 October 2017. On the recommendation of the Review of Ireland’s Corporation Tax Code undertaken by Mr. Seamus Coffey, the 80% cap was reinstated to ensure some smoothing of corporation tax receipts over time. For the purposes of certainty, changes to tax law are generally made on a prospective basis such that they apply only from the date on which they have legal effect. This measure, therefore, does not apply retrospectively.

It should be noted that the operation of the cap is simply a timing matter, and to present tax paid in current years as a result of the cap as additional tax for the Exchequer would not be correct. The measure has no effect on the overall quantum of capital allowances for intangible assets available to use against the relevant trading income. Any amounts restricted in one accounting period as a result of a cap are available for carry forward and use in a subsequent accounting period, subject to the application of the cap in that period. Income generated by assets onshored during the period when the cap was not in place will therefore be taxed going forward when the capital allowances have been fully used. The allowances are one of a number of measures designed to enhance the competitiveness of Ireland as a location for companies to develop intellectual property. This recognises the fact that investment and growth in OECD economies is increasingly driven by investment in intangible assets.

I have raised this with the Minister on numerous occasions. I argued passionately at the Oireachtas Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach that while reintroducing the 80% cap was a positive step, allowing the intellectual property that was being brought onshore to continue to claim the 100% was wrong. It is costing the State €750 million. The parameters of next year's budget, which we now know will be at €1.8 billion, could be increased by just changing this policy. The person that the Department of Finance commissioned to write the definitive report in respect of taxation has argued this should be introduced. It is not about retrospective taxation. There is nothing retrospective about this.

Mr. Seamus Coffey has said that it does not change the amount of capital allowances that are available and the total quantum of capital allowances remains the same. He has said that all that changes is the amount that can be claimed in future years. It is about how we attach them in future years. There are serious questions on where this policy came from. Who decided to raise the cap to 100%? At whose bidding was that done? Other changes were made at that time as well. Those included extending the qualifications for intangible assets and the rules relating to transferring assets. At whose bidding did this happen and why is the Minister so reluctant to bring in another €750 million to the State this year? It could be used to invest in the housing, health or cost of living crises.

I have supplied information to the Deputy in the context of last year's Finance Bill on the contact between my Department and my predecessor across the period when that decision was made. On the question of the decision I made, I made it on the basis of consultation I had with my own Department. I have outlined to Deputy Doherty the contact I had with bodies and organisations in the run-up to the budget. As to why I made the decision that I did and why I am not looking to change it in the way the Deputy wishes, it is because I believe the regime we have in place is competitive and stable. There is great value in those qualities given the changes happening at the moment.

It is my assessment that if I were to make the change that the Deputy referred to, it would damage our ability to attract and retain intellectual property. That is an important feature in how we can retain jobs within our economy. The current regime is competitive. Changing it in any way would undermine that competitiveness. As Deputy Doherty knows and has acknowledged, the €750 million referred to, which is a tentative estimate from the Revenue Commissioners, is a question of the timing of tax revenue.

It is not necessarily the timing of taxation. These companies are highly mobile. Companies could defer their liabilities for ten years and there is no guarantee that they will be here in ten years or that the structure of the companies would mean that the taxation would be available then. They could move their profit centre to some other jurisdiction. Let us not pretend that is not a risk. The reality is that this is a policy choice. The Minister's officials told us that. There is no other reason for this. I am asking the Minister to apply the same tax rules to intellectual property brought onshore by a company last month as we should be applying to intellectual property that was brought on to this shore post 2015.

I refer to what the Minister is allowing companies to avail of in the tax code because of this flawed decision, for whatever reason or at whoever's bidding it was made. We know Apple is one of these multinational companies. This has been written about internationally and has brought shame to Ireland in respect of our tax code. Intellectual property has been brought to Ireland and it has been possible to write down effective tax very close to zero as a result of this. The Minister is saying that he is going to apply a different tax code to that intellectual property and a separate tax policy in respect of intellectual property that was here in the past year or may come in future years.

I re-emphasise that intellectual property was brought to our country in the past and there was an expectation of what taxing regime would apply to that intellectual property when it was moved into our jurisdiction. I believe we should maintain that taxing regime. We gave commitments on what our international tax structure was going to be. Investment took place on that basis. If we were to change it in the way Deputy Doherty suggests, it would undermine our ability to retain investment in our country.

He is correct that it is a policy decision. I made that policy decision and I stand over it on the basis of what the long-term competitiveness of our economy can look like. Deputy Doherty pointed out how mobile a company is that moves to Ireland and that it might decide to move again in future. That is correct. Many of the companies, however, that are involved in technology and research in Ireland have had long-term relationships with Ireland and have been based here for many years. I believe this is the right regime to maintain that long-term trading relationship with those companies.

Personal Contract Plans

Michael McGrath

Question:

9. Deputy Michael McGrath asked the Minister for Finance his views on the contention by the Competition and Consumer Protection Commission that personal contract plans, PCPs, should be covered by the Central Bank’s consumer protection code; and if he will make a statement on the matter. [21453/18]

This question relates to personal contract plans, PCPs. They are playing an increasingly important role in the car finance market. The Competition and Consumer Protection Commission published a report into PCPs two months ago. My main question relates to one of the recommendations on the application of the consumer protection code and who is going to take responsibility for that being done. The Minister might clarify if the Government accepts that recommendation and if it is going to move to implement the application of that code to these products.

Personal contract plans, PCPs, are a type of hire-purchase financing agreement used for the purchase of motor vehicles. They normally comprise three parts: an up-front deposit payment, ongoing monthly payments and a final payment at the end of the contract term. While the consumer will have the hire and use of the car, ownership of it remains with the finance provider. Hire-purchase providers are not required to seek authorisation from the Central Bank for the provision of hire-purchase agreements such as PCPs. The consumer protection code of 2012 is a binding statutory code on entities regulated by the Central Bank. As the category of hire-purchase provider is not authorised or regulated by the bank, however, the Central Bank advises that they are not subject, for the provision of a hire-purchase agreement, to the requirements of the code. There is, however, legislation governing the operation of hire-purchase agreements, and this is provided for in the Consumer Credit Act. Any entity providing hire-purchase agreements, or acting as intermediary in regard to such agreements, will have to comply with the relevant provisions of that Act. Both the Central Bank and the Competition and Consumer Protection Commission have certain functions under that Act. The bank has an overall role in relation to the operation of such agreements and the commission has a role in regard to the authorisation of credit intermediaries.

Nevertheless, it is important to keep this new and growing area of consumer finance under review. I welcome the publication of the recent report and the separate Central Bank economic letter on the market. These papers provide an important insight into the market. There are already important legislative provisions in place. Nonetheless, I am now examining the recent publications and will give careful consideration to what further actions, including consumer protection measures, would be appropriate in the light of the reports.

The issue is that there are gaps in regulation, the key one being that the provider of finance does not have to carry out any suitability check or affordability assessment of the product for the consumer. That is the key omission, and it needs to be dealt with. There are examples of where the product is exploited. If one looks this up online, one will see advertisements stating "Leave bad credit behind today" or "Drive away in your new car now." That is an example of the consequence of these products not being properly regulated.

We are talking about a product that has amassed a total debt of approximately €1.5 billion across over 126,000 transactions. There is nothing inherently wrong with PCPs but proper suitability checks are required. The affordability of the product has to be determined. What we now have is a game of pass the parcel between the Department of Finance and the Department of Business, Enterprise and Innovation over who will take responsibility for the products. Somebody has to. It needs to be done quickly.

There is no pass the parcel at all taking place in regard to these matters. The figures the Deputy has referred to are correct. Let us look at the amount of new lending in this category. In 2017, it was €835 million. This increased from €96 million in 2012. Therefore, it is a really significant increase. It is a matter that I am taking seriously. As I stated, I am examining the two publications and I will soon be deciding what further measures are needed in recognition of the scale of lending.

I thank the Minister. I welcome the fact that he is actively examining this issue. That needs to be done. Keeping the matter under review is not sufficient. The Minister now has an economic letter from the Central Bank and a detailed report from the CCPC with a number of recommendations.

The reality is that this product is currently falling between two stools in some respects. Since the contract is a hire-purchase contract, it is not a matter for the Central Bank in terms of the consumer protection code. There has to be a requirement on those providing the finance to assess the suitability of the product for the consumer. There has to be an affordability assessment. That is the key ask I am making of the Minister. A debt of €1.5 billion has been built up. The product is a really important one for the motor industry, and it is a means for consumers to get a new car. We want to protect that but the best way to do so is to ensure the product is properly regulated and that the gaps that have now been identified are filled as a matter of priority.

I will take a short supplementary question from Deputy Joan Burton.

Is the Minister aware that many young people are taking up these loans to purchase what are, for them, relatively expensive cars? There are very complex regulations governing the deal and when the purchase might come into the ownership of the individual. A lot of deals can fail towards the end of the period. The fact is that the young people then could get an adverse report in terms of their credit rating, which they will carry with them for a long period. Will the Minister examine specifically the social implication? When the young people seek a mortgage later on, perhaps with their partner, they will find they have an adverse credit rating. Nothing has been done to warn them of this or to prevent it.

In my response to Deputy Michael McGrath, I referred specifically to consumer protection law as something that needs to be considered in regard to this category of finance. It is a category of finance that has grown in the way I have described. I am aware of who might be gaining access to the finance and how it is used. I have received the reports over a number of weeks and I am now considering what further action needs to be taken, what new responsibility is required and who would need to discharge it.

NAMA Operations

Mick Wallace

Question:

10. Deputy Mick Wallace asked the Minister for Finance if he has discussed the Data Protection Commissioner's ruling on NAMA and a group (details supplied) with the NAMA CEO and chairman; the reason NAMA has not appealed the ruling; the steps NAMA is taking to ensure it is in full compliance with data protection law; and if he will make a statement on the matter. [21446/18]

This question relates to the ruling by the Data Protection Commissioner on NAMA and the O'Flynn Group. Could the Minister tell me whether he has discussed the ruling with the NAMA CEO and chairman? The last time we spoke about this, the Minister informed me the board of NAMA is currently considering the ruling of the commissioner and will respond to it. Could the Minister tell me whether there has been a response? What steps is he taking to ensure that NAMA is in full compliance with data protection law? Has he read the report?

I advise the Deputy that, as Minister, I play no role in the day-to-day operations of NAMA, which are set out in the NAMA Act 2009. As such, it is not appropriate for me, as a Minister, to discuss with NAMA how it should deal with an operational matter such as this. I can confirm, however, that my officials have been briefed on this matter. I am informed that, having considered the decision of the Office of the Data Protection Commissioner carefully and with the benefit of expert advice, NAMA has decided not to appeal the decision. I am advised that NAMA is instead working constructively with the Data Protection Commissioner and the parties concerned in dealing with the request, having regard to the guidance provided by the Data Protection Commissioner in the decision. In doing so, I am informed that NAMA has, since the decision, taken considerable steps to identify and isolate all potential sources of personal data it may continue to hold concerning the parties and fully address the issues raised in the decision.

This dataset was assembled some weeks ago and is in the course of being reviewed with assistance from an external provider with expertise in this area to identify the potential sources of personal data. I am advised that NAMA will begin to provide the output of this review to the parties concerned shortly. This will be done in batches given the quantity of data involved. The steps taken thus far, I am informed, have been notified to both the Data Protection Commissioner and the parties concerned, and NAMA has agreed to keep these parties updated on progress on this review.

I am glad to hear co-operation is being considered. I asked the Minister whether he had read the report. It would have made interesting reading for the Minister for Finance. If he had read it, he would have noted that the disdain and - for want of a better word - ignorance showed by NAMA not just for the O'Flynn Group but also for the Data Protection Commissioner, in particular, was a bit scary. I would be concerned if the Minister did not have concerns about that area.

The Minister gives me the impression he is not really responsible for holding NAMA to account.

Am I correct in my understanding of the Minister's comment? If he cannot hold NAMA to account, who can? It does not look as if anyone is doing so.

I assume that when the Deputy asks if I have read the report, he is referring to the ruling made by the Data Protection Commissioner. I have not read the ruling, but I do have the summary of the commissioner's views on the matter and an update on NAMA's response. On whether I hold NAMA to account, it has a business or strategic plan and is accountable to me for its implementation. I meet its chairman and chief executive regularly. The difference is where legal issues are raised by individuals about how they believe their rights need to be protected and action should be taken in that regard. I am not involved in how NAMA responds. It is a matter for its board and chief executive who engage directly with the Data Protection Commissioner and the Director of Public Prosecutions in other matters. I am not involved, but I have outlined the areas in which I am.

The Minister says it is a matter for the board of NAMA, but is it one for him, given that NAMA publicly rubbished the Comptroller and Auditor General, Mr. Séamus McCarthy, when he published his report? If he had been Minister at the time, would he have challenged NAMA on its treatment of Mr. McCarthy?

The Deputy should be careful in naming people.

It is funny if one cannot mention the name of the Comptroller and Auditor General here. Let us take all of the issues surrounding Project Eagle. We found out that some of Cerberus' money had ended up in an Isle of Man bank account. Does Minister think that in that case he is responsible for holding NAMA to account?

I wish to make two points, the first of which is that there must be accountability in this case, while the second is that we need to know if it has wider application. It was a significant ruling by the Data Protection Commissioner, that a very powerful State agency was in breach of the Data Protection Acts in the non-disclosure of personal information held by the agency on some borrowers. As public representatives, we are regularly in receipt of grievances from NAMA debtors and must make a call on how we should deal with them. There are certain issues that we are allowed to raise with NAMA, while not making representations in contravention of the Act. However, it can sometimes be difficult to get any information whatsoever. The ruling was that there had been a breach. We need an account of how it happened and to know if it has wider application in other incidences of non-disclosure by the agency on foot of the receipt of information requests.

Deputy Michael McGrath referred to Project Eagle. As he knows, an inquiry is under way and any decision on accountability will have to be dealt after it has been concluded. I hold the board and the chairman accountable for implementation of their business plan and published strategy. Should matters emerge from inquiries that take place which raise issues for NAMA, of course, I will also raise them with them. I am not aware of wider consequences of the ruling, but I know that when rulings such as this are made, there may be consequences for NAMA. I will raise the matter with it and respond to the Deputies.

Tracker Mortgage Examination

Pearse Doherty

Question:

11. Deputy Pearse Doherty asked the Minister for Finance the latest engagement he had with the Central Bank on tracker mortgage issues; if he raised the issues of prevailing rate customers, customers of a building society who have not returned to a tracker mortgage, staff tracker mortgages in a bank (details supplied) and other groups still not deemed to be impacted on by the matter; and if he will make a statement on the matter. [21433/18]

Last week the Central Bank told us that it was still in discussions with some financial institutions on some categories or groups of victims in the tracker mortgage scandal. We know how pressure has been brought to bear on the financial institutions, at a political level from the Minister's Department or by the stories of the victims. However, I am concerned that we are not yet done in dealing with the issue. We are so far into it, yet I am concerned that time is slipping and that there are still queries or disputes between the Central Bank and the financial institutions. We have received many emails from individuals who are disgruntled at decisions that they are not within the scope of the inquiry.

In April the Central Bank provided me with a comprehensive update on the tracker mortgage examination. It subsequently published the update on its website. The report indicated that an additional 3,400 impacted on accounts had been identified since the previous December progress report, bringing the total number of impacted on accounts to 37,100. Progress has been made in the payment of redress and compensation. A total of €412 million has now been paid in respect of 88% of accounts so far identified as impacted on and verified pursuant to the examination. This is additional to the €47 million paid in redress and compensation to impacted on customers identified outside the scope of the industry-wide examination.  

In line with its engagement with lenders via the examination the Central Bank, as independent regulator, has intervened on prevailing rate issues. This intervention is aligned with the Central Bank’s functions as part of the examination to rigorously test and challenge, from a systemic perspective at the macro level, the position adopted by lenders in order to try to achieve the best result for all customers within a group.  

One of the lenders which indicated that there was an issue with the prevailing rate was AIB.  The matter was pursued by the Central Bank and directly as a result of its intervention, AIB prevailing rate customers were admitted to the examination and will receive a compensation payment, as well as an offer of the current prevailing rate, as opposed to the prevailing rate at the time their fixed rate expired.  By securing their admission to the examination, the Central Bank has also ensured those customers will have the opportunity to utilise the examination’s appeals processes should they be dissatisfied with any aspect of their redress and compensation offer and can pursue their case, based on their own unique circumstances, with the Financial Services and Pensions Ombudsman. In the particular case the Central Bank examined AIB’s model to determine the then prevailing rate and concluded that it was reasonable in relation to the contractual interpretation of the term "prevailing rate”. The bank also advised me that it had formed the view that, at a macro level, it could not mount a legal challenge on behalf of all customers in the relevant group on this issue.  Nevertheless, more generally it advises that it continues to engage with and challenge lenders on a number of tracker mortgage issues which include the prevailing rate.

The prevailing rate has been a serious bone of contention for many individuals. My colleagues on the finance committee and I have quizzed all of the financial institutions about the prevailing rate, where they accepted that a customer should be on that rate, but it was 3.5%. What they came up with was ridiculous and we queried it with the Central Bank. When officials of the Central Bank appeared before the committee in recent weeks, I put the issue to them. They told us "it is clear that the prevailing rate issue has been dealt with in some of the entities." That was the first time we had received information that that was the case in AIB. I welcome being able to give that information. We will tease out the matter with AIB when its representatives come before the committee soon. However, the Central Bank has stated it is still in discussions with others. There are people who do not know if their issue with the prevailing rate with Permanent TSB, Bank of Ireland or any other bank has been closed, whether they should go to the Financial Services Ombudsman or if the Central Bank is still arguing on their behalf. Will greater transparency be brought to this issue in order that customers will know where they stand?

I will answer the Deputy's question, but I wish to return to two other matters related to staff loans included in the Deputy's original question. The Central Bank has made it clear to lenders that their staff, who have impacted mortgage accounts, are to be included in the examination in the same way as all other impacted customers.

The Central Bank has now indicated that it is satisfied that all impacted customers have been identified at this point. In overall terms, however, while the bank is currently of the view that the majority of affected customers have now been identified, it nevertheless expects that there will be some further increase in the number of impacted accounts before the conclusion of the examination. This is an ongoing matter. I do not expect the number of accounts to move up in the way it has in the past where it moved up by such a quantum, but it is entirely possible it could move up again.

On transparency, I have also had a lot of contact on the matter from constituents and citizens and the general view I have received is individuals have understood where they stand on the process. If the Deputy has specific examples of where he believes that is not the case, he might share those with me and with the bank director.

On the issue of staff loans, I received an email this morning from an employee in Bank of Ireland and it is quite interesting given the revelations in the national media this morning that Bank of Ireland's chief who has a mortgage of €2.8 million is servicing that mortgage with a payment of €1,400 per month. That is less than the current average rent in Dublin and it shows how these banks can fleece their customers with the highest interest rates in Europe, as we have seen from the Central Bank's report last week, but how they also treat their customers. This employee in Bank of Ireland was just informed that they are not impacted, despite the fact that the staff were told at the time that they would roll onto a tracker and that they did not have to do anything but then the carpet was pulled from under them. I make the point that there are still unresolved issues on some of this and we need to continue to encourage, support and challenge the Central Bank in dealing with these outstanding issues.

To add to what Deputy Pearse Doherty said, it is really important that at this late stage people are told where they stand because there are various strands of outstanding issues here and the Central Bank is clearly moving towards a conclusion on all these issues. There will be legal challenges on certain issues. That is absolutely certain at this stage.

The other key point I want to make is that while I welcome the fact that there are six enforcement investigations under way, the elephant in the room is the following question. Why did this happen and how could this happen across all the main lenders in the same way in a manner that was disadvantageous to the consumers and advantageous to the bank? That is the question that has to be answered and at the end of the day, if we are to have any accountability for what has happened, that question must be answered.

Deputy Pearse Doherty said that this matter is still unresolved and unconcluded. I agree with him, it is. Deputies have raised a number of issues with me, as I have dealt with this matter, on where we were with staff loans, where the Central Bank was with staff loans and where we were with the issue on the prevailing rate of interest. I have now updated the House on where that stands. On the information the Central Bank has shared with me on where individuals stand, I would expect that as the investigation moves into the final stage of its work, that all individuals will know where they stand at the end of it. That is not to say every individual will be satisfied. People may take further action and I acknowledge that could happen, but I believe the appeals process that has been put in place is comprehensive. I restate that if an individual has received payment, that payment is then his or her and it will not be affected by any future participation he or she has in the appeals process.

On the question about why this happened, that is a question that I expect the Central Bank will be able to answer in the inquiry report that will be at the end of this process. As I have said on a number of occasions, this should not have happened and it should not have taken this long to resolve. The Central Bank, despite views that have been articulated to it, has risen to the challenge in dealing with what was a very complex issue which has inflicted much loss on many of our citizens.

Common Consolidated Corporate Tax Base Proposals

Thomas P. Broughan

Question:

12. Deputy Thomas P. Broughan asked the Minister for Finance the strategies he is developing to mitigate shocks to corporation tax revenues arising from President Macron's proposed 2019-2020 EU reforms or other factors from 2019-2020; and if he will make a statement on the matter. [21385/18]

I know the Minister is an avid reader and follower of international affairs. Obviously, he read President Macron's book Revolution and his Sorbonne speech. What preparations, if any, is the Department making on the common consolidated corporate tax base on the impacts it will have on corporation tax and on the idea of a common finance Minister for Europe and a common debt? Are we doing anything? Perhaps this is the real elephant in the room. Are we doing anything to prepare for the possibility of these so-called reforms?

I have not read the book but I did read of the speech. I might ask the Deputy if he read either but I am sure he has. On the different issues he has referred to, President Macron, in his speech, referred to a defined corridor for corporation tax rates and increased convergence and called for a rethink on the taxation of digital companies. EU member states are currently discussing and debating various aspects of the common consolidated corporate tax base, CCCTB. By its nature, it is very complex and detailed. We are engaging constructively with the proposal but at the same time very carefully and critically analysing whether any aspect of it is in line with our long-term interests. To restate, tax remains a matter of member state competence and unanimity is required before any proposals can be agreed.

In respect of digital tax proposals, the Deputy will be aware that on 21 March the European Commission published two directives. One was temporary and one was comprehensive. There was an interesting discussion between Ministers at the informal ECOFIN in Sofia and it is clear that many countries have differing views on the merit of these proposals.  There is common ground among all member states that a sustainable, globally agreed solution is preferable to the EU acting alone.  Member states remain divided on the merit or need for interim measures.

The Commission’s current proposal, if adopted, would result in a significant shift in how corporate tax is administered and would have many unanticipated and negative consequences for EU member states and companies. Therefore, it is crucial that they are properly considered and analysed as they are hugely complex. I restate that unanimity is required before any proposals can be agreed.

There is a very serious move to bring in this equalisation levy on digital companies across the European area. Is the Minister saying that this is something he will steadfastly resist and that he expects the Taoiseach and the Government to continue to resist it? Does he see it as inevitable that digital products will be taxed in the country where the sales take place? On the CCCTB, the European directive in 2016 seemed to indicate that having common tax base rules was a very serious objective. That would have huge implications for our corporation tax on tax expenditures and the way we would frame it. Mr. Seamus Coffey, who I think is appearing before the Committee on Budgetary Oversight this afternoon, said that corporation tax is sustainable until 2020 or so but after that we are not so sure and we have had volatility in the past. Would the Minister regard these proposals emanating from the new French President, Mr. Macron, as a red flag that we need to keep a close watch on?

From a Fianna Fáil perspective, we view both the CCCTB and the digital taxation proposals as a step towards tax harmonisation across the European Union. From our perspective, this is an encroachment into an area of national competence and key national sovereignty. If necessary, the Minister needs to exercise the veto on these proposals. The Minister is doing what we would expect him to do in building alliances with other countries that would have a common view on this issue but if it comes to it and if these proposals are put, they need to be rejected and vetoed, if necessary.

I will not support any change that infringes the tax sovereignty of this country or poses any challenge to our ability to create and attract jobs here. As acknowledged by Deputy Michael McGrath, I am working with many like-minded countries on these matters. At this point, there is considerable concern in regard to both an interim measure and the development of a common consolidated corporate tax base that stretches well beyond Ireland, and this will become evident in the negotiations that are under way.