Claims for relief from double taxation ("correlative adjustments") arise in Ireland as a result of an upward adjustment to company profits in a country with which we have a double taxation treaty. A company may make a claim for a correlative adjustment to Revenue in Ireland where tax paid in the other country is increased as a result of such an upward adjustment and the associated company in the other country has agreed to such upward adjustment. Each claim is examined by Revenue and an appropriate amount of relief from double taxation is agreed. The number of correlative adjustment claims and the amount of tax relief granted in respect of those claims for each of the years 2005 to 2011 is shown in the table. The countries and industry sector involved are also listed in the table.
Finally, I am informed by the Revenue Commissioners that their obligation to observe confidentiality in relation to the tax affairs of taxpayers or small groups of taxpayers precludes them from providing the information requested by the Deputy in relation to the amount of tax involved in the 3 largest cases.
|
Number of claims received
|
|
Amount of tax relief granted *
|
|
2005
|
6
|
5 (1 claim not allowed)
|
€35.9m
|
|
2006
|
14
|
11 (2 claims were withdrawn and 1 is still open)
|
€101.7m
|
|
2007
|
8
|
8
|
€163.4m
|
|
2008
|
15
|
10 (1 claim was withdrawn and 4 claims are still open)
|
€315.7m
|
|
2009
|
13
|
9 (1 claim was withdrawn and 3 are still open)
|
€77.5m
|
|
2010
|
16
|
6 (10 claims are still open)
|
€51.7m
|
|
2011
|
8
|
1 (7 claims are still open)
|
**
|
*Note that the 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 is not considered appropriate as it could lead to identification of the company.
Countries involved
Australia, Belgium, Canada, Denmark, France, Germany, Italy, Netherlands, Spain, Sweden, UK, USA.
Claims by industry sector
Energy, Financial Services and Insurance, Food and Drink, General Manufacturing, Health care and Medical Devices, Hospitality, Information Technology, Retail, Transport.
