As I have said in answer to other Parliamentary Questions, company profits charged in Ireland fully reflect the functions, assets and risks located here by multinational groups. Profits charged here are aligned with real economic activity here - and these profits are charged at 12.5%. Very low rates computed in some cases are got by dividing the Irish tax by the sum of Irish profits and foreign profits of multinational companies. International tax planning opportunities largely arise from the interaction of different countries’ national tax laws and from international tax rules not keeping pace with current organization of multinational business. Addressing such issues comprehensively is beyond the scope of individual national tax systems or bilateral agreements between them.
The way to deal with international mismatches, gaps and loopholes effectively is for countries to work together on a multilateral basis to consider how national rules can be coordinated and international rules can be amended to address these issues. Ireland is committed to this approach and supports the OECD’s Base Erosion and Profit Shifting (BEPS) project, which is specifically concerned with addressing these issues. Ireland has concluded tax treaties with all member countries of the OECD, all of which have signed up to the BEPS project.