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Wednesday, 24 Oct 2012

Written Answers Nos. 54 - 58

Tax Code

Questions (54)

John Halligan

Question:

54. Deputy John Halligan asked the Minister for Finance if he will explain the way in which taxes (details supplied) are used and the matters they fund [46684/12]

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Written answers

Generally speaking all revenues of the State, including tax revenues are paid into the Central Fund. They are not assigned to specific areas of expenditure but rather form part of the pot from which overall Exchequer expenditure is funded. However, it is the case that receipts from the Household Charge are directed to the Local Government Fund, rather than the Central Fund.

The Department of Public Expenditure and Reform published the Revised Book of Estimates (REV) for 2012 in February. The REV sets out the voted expenditure allocations for every Government Department and Office. A breakdown of expenditure from the Local Government Fund is shown on page 114 of the 2012 REV.

Similarly, receipts from PRSI are allocated to the Social Insurance Fund (SIF) and the National Training Fund (NTF), rather than the Central Fund. The bulk of receipts go to the SIF. Spending from the SIF is directed to benefit schemes. A complete breakdown of expenditure from the SIF can be found in the 2012 Further Revised Estimate for the Department of Social Protection. It should be noted that as the income of the SIF is presently insufficient to cover all of its expenditures, a subvention is required from the Exchequer to meet the shortfall. Expenditure under the NTF supports training and the identification of skills needs. A breakdown of NTF expenditure can be found on page 133 of the 2012 REV. It should be noted note that the estimated income from contributions on the NTF in 2012 has been revised to €300.8 million.

PAYE, Universal Social Charge (USC) and DIRT receipts form part of income tax and are paid into the Central Fund. They are therefore available, along with other sources of tax revenue, non-tax revenue and capital receipts as well as the funds sourced from borrowing, to fund overall Exchequer expenditure.

Financial Services Regulation

Questions (55)

Arthur Spring

Question:

55. Deputy Arthur Spring asked the Minister for Finance the extent of Central Bank of Ireland supervision and control over bank fees and charges for retail customers in the context of diminished competition due to the reduced number of banks providing retail banking services here. [46768/12]

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Written answers

The Central Bank has advised me that under Section 149 of the Consumer Credit Act, 1995 (as amended), credit institutions and bureaux de change must notify the Central Bank if they wish to:

- Introduce any new customer ‘charge’ for providing a service or

- Increase any existing customer ‘charge’ for providing a service.

The Central Bank assesses these charges based on four criteria set out in the legislation:

- The promotion of fair competition;

- The commercial justification submitted in respect of the proposal;

- The impact new charges or increases in existing charges will have on customers;

- Passing on costs to customers.

The Central Bank may either approve or reject an institution’s application under Section 149; an institution may choose not to apply charges for which it already has approval for commercial or competitive reasons and then subsequently apply such charges in its own time. However, an institution may choose to apply such internal account structures at its own discretion and so the Central Bank has no power in this area to approve/reject such revisions.

In December 2011, the Central Bank of Ireland published the findings of research into charges applied by the main retail banks to personal current accounts. The research found that customers whose accounts go into an unauthorised overdraft position pay the highest fees. The highest current account costs occur when consumers have high numbers of out-of-order transactions occurring on their account such as unauthorised overdrafts, unpaid direct debits and over-limit or referral fees. Customers may make savings by using electronic transactions in place of manual transactions, where possible.

If customers are not satisfied with their current account provider for any reason, including cost of fees, they have the right to switch to a different provider. A copy of the Central Bank’s Consumer Protection Code including Code of Conduct on the Switching of Current Accounts with Credit Institutions and a review of personal current account charges is available on the Bank’s website www.centralbank.ie.

Notwithstanding the fact that the State is a significant shareholder in some banks, it is imperative that all banks are run on a commercial, cost effective and independent basis to ensure the value of the banks as an asset to the State.

Tax Avoidance Issues

Questions (56)

Maureen O'Sullivan

Question:

56. Deputy Maureen O'Sullivan asked the Minister for Finance if he will explain the recent tax figures released regarding a company (details supplied) paying only €35,000 in Irish taxes since 2005 while paying €5.7 million in royalty and licensing fees to its parent company; his response to the fact that companies like these can cut their income tax by paying fees to its parent company making it look like they are at a loss and are therefore not obliged to pay income tax; if he will consider measures to prevent this even though they are currently legal activities; and if he will make a statement on the matter. [46828/12]

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Written answers

I am precluded from commenting on the tax affairs of any taxpayer, as these are confidential between the taxpayer and the Revenue Commissioners. However, I am aware of recent media reports which refer to the ways that some companies structure their international tax affairs to minimise their tax costs. The ability of entities to reduce their tax liabilities using international structures reflects the global context in which Ireland and indeed all countries operate. In general, companies are required to pay corporation tax in the country where they carry on the economic activity, not necessarily where their customers are located. It is important to state clearly that all companies in Ireland pay the standard 12.5% rate on their trading profits which are generated in Ireland.

I wish to advise the Deputy that the Taxes Consolidation Act 1997 requires a company’s trading profits to be computed in accordance with generally accepted accounting practice subject to any adjustment required by tax law. In computing such profits, expenses that are incurred wholly and exclusively for the purposes of the trade, including royalties or licence fees paid for the use of intellectual property, are deductible. Subsidiaries of multinational groups, whether located in Ireland or other countries, will necessarily incur certain bona fide expenditures including, for example, royalty payments to group companies in foreign jurisdictions for the use of intellectual property rights. Such payments represent the required remuneration of valuable intangible assets funded and owned outside the State. Ireland cannot expect to receive or retain the remuneration of these assets. Nevertheless, Irish resident companies are chargeable to corporation tax at the standard 12.5% rate on the full trading profits that are generated from their economic activities here.

The tax code contains transfer pricing rules that apply the OECD’s arm’s length pricing principle to trading transactions between associated companies. This ensures that the profits chargeable to corporation tax in Ireland fully reflect the functions, assets and risks located here by a multinational group. As with any other rules in relation to the computation of income for tax purposes, the transfer pricing rules include provision for any adjustments to income and tax payable to be made if required. I would emphasise that Ireland is fully supportive of international efforts to ensure fairness in taxation. Ireland participates fully in the EU Code of Conduct Group, which addresses harmful tax competition, and in the OECD Forum on Harmful Tax Practices.

Credit Unions Regulation

Questions (57)

Finian McGrath

Question:

57. Deputy Finian McGrath asked the Minister for Finance his views on correspondence (details supplied) regarding the Credit Union Bill [46841/12]

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Written answers

The Credit Union Bill 2012 is consistent with the Final Report of the Commission on Credit Unions, which was agreed over a nine-month period by all Commission members, including the Irish League of Credit Unions. The Credit Union Bill delivers on over 60 of the recommendations in the Commission Report, as the following table clearly shows. The Commission included representatives of the Irish League of Credit Unions, the Credit Union Development Association, the Credit Union Managers Association, the Central Bank and the Department of Finance, as well as independent members. The Commission met 29 times between June 2011 and 30 March 2012.

The Commission sought direct engagement from credit unions to ensure that its recommendations took account of a broad range of perspectives. A consultation process sought submissions from members of the public and interested parties that would facilitate the good functioning of the Irish credit union movement into the future. The submissions received were used to inform the Commission’s final report. Furthermore, the Commission undertook a survey of credit unions in Ireland which sought the opinions of credit union boards on a wide range of issues. The Commission also received a number of presentations, including from those within the credit union movement.

The Commission members took a hands-on approach to the Report and the ILCU was centrally involved in its development, drafting and finalisation. The ILCU is not only a signatory to the agreed report, but a co-author of it. If we are to build confidence in credit unions it is important that all those who drafted and agreed the Commission report continue to stand behind it. The difficulties being faced by credit unions and the scale of the challenge ahead require steadfastness and leadership at all levels of the movement.

The Government has already shown its commitment to the credit union sector by putting aside a figure of €500m to address problems within the sector at a time when the Government faces difficult budgetary choices and competing needs for scarce resources, there is an onus on the credit union movement to embrace the necessary changes to ensure that this commitment on behalf of the taxpayer delivers a viable sector into the future.

The Government’s commitment to implementing the Commission Report is backed by solid early delivery of major elements of it:

- the publication of the Credit Union Bill 2012 (which implements over 60 recommendations);

- the commencement of contributions under the Deposit Guarantee Scheme and fitness and probity; and

- the appointment of the Credit Union Restructuring Board and the early commencement of its work.

In order to ensure full implementation of the Commission Report, I have established an Implementation Group which includes representatives from the Irish League of Credit Unions, the Credit Union Development Association and the Credit Union Managers Association; the Chair of the statutory Credit Union Advisory Committee; a former member of the Commission on Credit Unions; and representatives from the Central Bank and the Department of Finance. I have asked my officials to arrange for the issues raised in the correspondence to be considered at the next meeting of that Group.

In terms of legislation, the vast bulk of the core provisions to apply to credit unions will be set out in the Credit Union Act 1997 and the Credit Union Bill 2012. However, as recommended by the Commission Report, the Credit Union Bill 2012 seeks to rectify the legal issues surrounding section 184 of the Credit Union Act 1997, which purports to disapply the Central Bank Acts as far as credit unions are concerned, but which has merely served to create legal doubt on this point. In revisiting section 184, care has been taken to avoid substantive new policy provisions applying to credit unions arising from what is a largely technical amendment. For that reason provisions such as section 117 of the Central Bank Act 1989 (and the Central Bank codes made under it) and Part IV of the Central Bank Act 1997 (relating to auditors and compliance statements) are disapplied under the Bill.

However, with regard to the Central Bank Acts and other financial services legislation it is also important to understand that the agreed Commission Report cannot be implemented if credit unions are to be excluded from their remit:

- The provision for credit unions to appeal to the Irish Financial Services Appeals Tribunal is provided for in Part VIIA of the Central Bank Act 1942;

- The facility for credit union members - and indeed credit unions themselves - to continue to seek redress through the Financial Services Ombudsman relies on Part VIIB of the Central Bank Act 1942;

- The application of the administrative sanction regime to credit unions relies upon Part IIIC of the Central Bank Act 1942;

- The application of fitness and probity to credit unions relies on Part 3 of the Central Bank Reform Act 2010;

- The resolution powers which the Commission recommends to be applied to credit unions where appropriate are set out in the Central Bank and Credit Institutions (Resolution) Act 2011.

It is not the case that the Central Bank Acts are banking legislation. The principal domestic Act dealing with the establishment of banks is the Central Bank Act 1971. The references in that Act to credit unions are specifically required to ensure that credit unions are not subject to a banking regime; for example, by exempting credit unions from the requirement to obtain a banking licence in order to accept members’ savings.

It is worth noting that several other pieces of legislation already apply to credit unions and have done so for many years.

- The application of regulatory levies to credit unions has for many years applied to credit unions under the Central Bank Act 1942;

- The insuring of savings at credit unions relies on the application of the Financial Services (Deposit Guarantee Scheme) Act 2009;

- The establishment and operational arrangements for the Registrar of Credit Unions itself are set out in the Central Bank Act 1942.

In the broader financial services area, and as part of their core work, credit unions are already subject to a wide range on non-credit-union-specific legislation, such as the Consumer Credit Regulations 2010, the Criminal Justice (Terrorist Offences) Act 2005, the Criminal Justice (Money Laundering and Terrorist Financing Act) Act 2010 as well as other legislation of general application, such as the Equality Acts and the Data Protection Acts. In fact, many credit unions have become able to offer an improved range of services to their members by actively securing authorisation from the Central Bank beyond the confines of the Credit Union Acts under the Insurance Mediation Regulations 2005, the Investment Intermediaries Act 1995 and the European Community (Payment Services) Regulations 2009.

The Commission specifically recommended that the powers and functions intended under the Supervision and Enforcement Bill 2011 be applied to credit unions. Restating these provisions in the Credit Union Bill would have no different legal effect and would create needless duplication in the drafting and parliamentary processes, thereby delaying the reforms to no discernible advantage. My Department is currently considering the issue of an appeal mechanism from directions issued by the Bank under the Supervision and Enforcement Bill and has already met with ILCU to discuss the matter.

With regard to term limits, it is important to note that the Commission was charged with bringing forward recommendations for the Irish credit union sector and that it was not bound to limit its thinking to approaches in place in other financial sectors or in other jurisdictions. I understand that the Commission recommendation on term limits was the subject of much discussion at the Commission and that the ILCU was centrally involved in the development of the final recommendation, which was clear and unambiguous as regards the limits to apply. The Commission recommendation is reflected exactly in the Credit Union Bill 2012.

The position regarding exclusions from Board membership also reflects the Commission recommendation and the discussion at the Commission when it considered the General Scheme of the Bill. The ILCU played a full part in considering and agreeing the balanced set of exclusions to apply, which are aimed at underpinning good governance and avoiding conflicts of interest.

The correspondence referred to in the question raises concerns about the removal of the role of the treasurer. Retaining the role of treasurer would conflict directly with the recommendations of the Commission report. In order to ensure that the role and responsibilities of board and management do not overlap and that board members have governance rather than executive responsibilities, the Commission specifically recommended that the 1997 Act be amended to remove the role of treasurer and assign executive responsibilities to the management of the credit union. However, cognisant of the fact that credit unions are financial institutions, the Commission recommended that the board should include at least one director with specialised expertise, qualifications and background in financial services and/or accounting matters.

Volunteers are central to the success of the credit union movement and to its path towards a viable future. The Commission’s agreed report, and the Credit Union Bill which flows from it, retains the voluntary nature of the movement and provides for proper training and development of directors and other volunteers, succession planning and for greater clarity as regards the roles and responsibilities of those in key positions within credit unions, voluntary or otherwise. This will position well-run credit unions to attract talented and qualified volunteers within the community who see the benefit of self-development through the training, skills and experience to be gained at credit unions. While participation at board level is an important role, it is equally important to give due credit to the valuable contribution that may be made by volunteers in non-board roles, including by former directors in training and nurturing future board members.

The Commission report recognises that volunteers are crucial to the continued success of the movement, and that it is important that credit unions consider fully the role of volunteers when planning their business strategy. The Commission recommends a planned effort by credit unions to seek-out potential candidates with the necessary levels of skill and commitment, and a greater use of succession plans and volunteer development strategies. The ILCU can play an important part here, as the Commission Report notes that, given that this is likely to be a movement-wide issue, there may also be a role for representative bodies in providing promotion and marketing, as well as advice on how best to identify, engage and train new volunteers.

In relation to the size of the tiers, the Commission Report recommends a tiered approach to the regulation of credit unions and sets out, for illustration purposes only, how such a tiering might work. The Credit Union Bill specifically provides that requirements being applied to credit unions may be calibrated according to the nature, scale and complexity of the credit unions or categories of credit union concerned. This is in line with the approach recommended by the Commission and appears to address the concern about regulatory requirements being limited to considerations of asset size alone.

The Commission recommended that the establishment of shared service arrangements should be facilitated, by legislation where necessary. There does not appear to be any obstacles in the current legislation or in the Bill to setting up credit union service organisations (CUSOs) to enable the sharing of services between credit unions. Indeed the Credit Union Bill facilitates such arrangements by allowing flexibility for Central Bank regulations on investments by credit unions and by specifically providing a framework for the outsourcing of credit union operations. These changes will help to facilitate the development of shared services arrangements by credit unions.

In relation to Social Finance, the Commission Report recommends that the role needs to be carefully designed to integrate prudently with the basic credit union business of savings and lending services for individuals. The Commission also recommends that a formal process of engagement be established between the credit union representative bodies and Government to determine safe ways to invest collective credit union funds into community projects, employment initiatives and small co-operatives. I remain open to proposals from the credit union movement on this front and it does not appear that primary legislation is required in order to facilitate this.

In the case of electronically enabled payment accounts, there does not appear to be any obstacles in the current legislation or the Bill to the development of these initiatives, and indeed many credit unions already offer such payment accounts.

The Commission recommended that a consultation protocol should be in place between the Central Bank and credit unions. This protocol is to be developed following consultation between the Central Bank, myself as Minister for Finance, credit union representative bodies and the Credit Union Advisory Committee. The protocol is to set out how the Central Bank proposes to engage with credit unions in any formal consultation process prior to the introduction of new regulations. The protocol may provide for varying levels of consultation depending on the nature and complexity of the regulation being proposed. This will have the effect of increasing transparency and confidence in the regulation making process. This protocol is to include the specific requirement that consultation does not impact on the statutory independence of the Central Bank in the regulation of credit unions. I understand that a draft of the protocol has already been circulated to stakeholders for comment and that the ILCU has made a submission which is being considered by the Central Bank.

The Credit Union Bill was published in 28 September 2012. It will be debated in the Dáil in this session and I will consider on their merits any amendments proposed.

Index of the Credit Union Bill 2012 linked to the recommendations in the Report of the Commission on Credit Unions (“CCU”) and the Credit Union Act 1997 (“CUA”)

Part/

Section

Section title

CCU paragraph

PART 1:

PRELIMINARY AND GENERAL

N/A

PART 2:

AMENDMENTS TO CREDIT UNION ACT 1997 AND CONSEQUENTIAL AMENDMENTS

Chapter 10 and Chapter 11 of the CCU Report

6

Amendment of section 2 (interpretation) of Principal Act

N/A – these amendments are consequential arising from amendments to the CUA outlined in this Bill

7

Supplemental provisions relating to registration, etc., under section 6

Annex 1 to Chapter 10

8

Savings

10.3.27

9

Protection of members’ savings

10.3.14

10

Borrowing

10.3.28 &

s. 33(4) - 33(5) CUA

11

Lending

10.3.25 - 10.3.26 & section 35 (7),(8) & (10) CUA

12

Investments

10.3.22 - 10.3.24

& section 43 CUA

13

Reserves

10.3.15 - 10.3.18

14

Appeal against certain decisions of Bank

Annex 1 to Chapter 10, and 10.5.9 of the CCU report

15

Board of directors – This section inserts a new section in the place of section 53 CUA:

Subsection 1

Subsection 2

Subsection 3

Subsection 4

Subsection 5

Subsection 6

Subsection 7

Subsection 8

Subsection 9

Subsection 10

Subsection 11

Subsection 12

Subsection 13

Subsection 14

Subsection 15

Subsection 16

Subsection 17

Subsection 18

Subsection 19

11.3.27

11.3.12

11.3.12

11.3.14

11.3.16

s. 53(3) CUA

s. 53(4) CUA

s. 53(5) CUA

s. 53(6) CUA

11.3.17

11.3.17

11.3.24

11.3.25

11.3.53

11.3.53

s. 63 (2) CUA

s. 54 (3) CUA

s. 54 (4) CUA

s. 54(5) CUA

16

Operation of board of directors – new section 54 CUA:

Subsection 1

Subsection 2

Subsection 3

Subsection 4

Subsection 5

Subsection 6

Subsection 7

Subsection 8

Subsection 9

Subsection 10

Subsection 11

Subsection 12

11.3.65

11.3.38

Section 54(2) CUA

11.3.66

11.3.67

11.3.27

11.3.68

11.3.69

11.3.70

11.3.71

11.3.72

11.3.72

17

Functions of the board of directors – new section 55 CUA

Subsection 1

Subsection 2

Subsection 3

Subsection 4

Subsection 5

Subsection 6

Subsection 7

Subsection 8

Subsection 9

Subsection 10

11.3.27

11.3.57

11.3.20

11.3.21

11.3.22

11.3.26

11.3.40

11.3.4

Section 55 CUA

11.3.29

11.3.59

11.3.62

11.3.62

11.3.30

11.3.30

11.3.31

11.3.73

11.2.3

18

Chair of board of directors, etc.

11.3.36 - 11.3.39

19

Board committees - new section 56A.

11.3.73 – 11.3.84

20

Nomination committee

Subsection 1

Subsection 2

Subsection 3

Subsection 4

Subsection 5

Subsection 6

Subsection 7

Subsection 8

Subsection 9

Subsection 10

Subsection 11

Subsection 12

Subsection 13

11.3.46

Sch 3 of the 1997 Act

11.3.46

11.3.16

11.3.47

11.3.48

11.3.51

11.3.52

11.7.13

11.3.47

11.7.13

11.3.52

11.3.48 – 11.3.49

11.3.49

11.3.50

11.3.52

11.3.52

Sections 53(2) and 54(3) CUA

21

Manager of credit union. – new section 63A of CUA

11.3.40 – 11.3.45 and 10.3.32

22

Credit officer and credit control officer – new section 65 CUA

Section 65 CUA and 11.2.2

23

Directors: suspension and removal by board oversight committee – new section 66 CUA

Section 66 CUA and 11.2.5

24

General governance requirements

- new section 66A CUA

- new section 66B CUA

- new section 66C CUA

11.3.4, 11.3.5 and 11.3.7

11.3.4

11.3.9-11.3.10

25

Conflicts of interest – new section 69 CUA

11.3.32-11.3.35

Section 69(2) CUA

26

Additional requirements for credit unions

- new section 76A

- new section 76B

- new section 76C

- new section 76D

- new section 76E

- new section 76F

- new section 76G

- new section 76H

- new section 76I

- new section 76J

- new section 76K

10.3.30 and section 32B of the Central Bank Act 1942

10.3.31

10.3.32

10.3.32

10.3.34

10.3.35

10.3.35

10.3.35

10.3.35

10.3.35

10.3.35 and 11.3.63 – 11.3.64

27

Board oversight committee

- new section 76L

- new section 76M

- new section 76N

- new section 76O

- new section 76P

- new section 76Q

- new section 76R

- new section 76S

11.2.5

11.3.85

11.3.87, 11.3.91, sections 58(2), 59(4), 59(5) CUA

Sections 59, 60 and11.3.86

Sections 58(4) and 58(5) CUA

11.3.88 - 11.3.90

Section 61 CUA

Section 62 CUA

28

Special resolutions – new section 83 CUA

10.4.2, Annex 1 to Chapter 10 and section 83 CUA

29

Power of Bank to make regulations relating to prudential requirements, etc. – new section 84A CUA

10.3.8 - 10.3.14

30

Liquidity – new sections 85A and 85B CUA

10.3.19 – 10.3.21

31

Bank’s power to require appointment of additional director of credit union - new section 95A CUA

11.3.14

32

Removal of auditor of credit union by Bank – new section 116 CUA

Annex 1 to Chapter 10

33

General regulations by Bank – new section 182A CUA

10.4.12 and Annex 1 to Chapter 10

34

Certain enactments not to apply to credit unions, etc. - new section 184 CUA

10.4.13 and Annex 1 to Chapter 10

35

Miscellaneous and consequential amendments to Principal Act

10.4 and Annex 1 to Chapter 10

36

Amendment to Schedule 2 to the Central Bank Act 1942

10.5.7

37

Revocation of statutory instrument

Consequential amendment

PART 3:

RESTRUCTURING

9.6 - 9.11

PART 4:

STABILISATION

8.5.3 – 8.5.11

SCHEDULE:

MISCELLANEOUS AND CONSEQUENTIAL AMENDMENTS TO CREDIT UNION ACT 1997

10.4, Annex 1 to Chapter 10 and consequential amendments

Global Economic Forum

Questions (58)

Brendan Smith

Question:

58. Deputy Brendan Smith asked the Minister for Finance the progress that has been made on achieving global tax transparency; and if he will make a statement on the matter. [44903/12]

View answer

Written answers

I am pleased to be able to advise Deputy Smith that significant progress has been made in the area of achieving global tax transparency. The Global Forum on Transparency and Exchange of Information was established by OECD member countries and certain other jurisdictions in 2000. The Global Forum was significantly restructured in 2009 and now counts some 110 countries as members. The list of members is still growing.

All members of the Global Forum are committed to meeting the OECD standard in relation to transparency and exchange of information. The OECD standard covers the availability of certain taxpayer information and the ability to access that information and to supply it to another country when a valid request to do so is received— for example, under a Double Taxation Agreement (DTA) or a Tax Information Exchange Agreement (TIEA).

The type of taxpayer information that must be available for exchange covers, in the case of companies for example, the owners of the company and the accounting records of the company. The competent authority for exchange of taxpayer information under a DTA or TIEA (which in the case of Ireland is the Revenue Commissioners or their authorised representatives) must have powers to access information and then must exchange that information when a request is received that meets the conditions for exchange of taxpayer information which are laid down in the relevant DTA or TIEA.

In order to ensure that the OECD standard is being met the legal and regulatory framework (Phase 1 review) and practical experience of exchange of taxpayer information (Combined review) in all members of the Global Forum is currently being reviewed. Since the first review was launched in 2010 the Global Forum has adopted and published the reports of over 60 Phase 1 reviews and over 20 Combined reviews— including the report of the Combined review of Ireland, which was published in January 2011. The reviews published to date contain recommendations as to how the member countries concerned could improve their legal and regulatory framework and practice and there is an effective follow-up programme to ensure recommendations are implemented.

Since 2009 an additional 800 DTAs and TIEAs have been signed and many countries are now signing and ratifying the Joint Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters which also provides a legal basis for exchange of taxpayer information. This increase in the number of instruments to exchange taxpayer information is also changing the “global tax transparency” landscape. The G20 has strongly endorsed the work of the Global Forum and recommended that countries join it. As set out above, it is clear that the Global Forum has made significant progress in achieving global tax transparency.

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