I propose to take Questions Nos. 206 and 209 to 211, inclusive, together.
I have been advised by Revenue that exchange of information carried out under the provisions of Ireland’s international agreements including double taxation treaties and the Council Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation is governed by strict confidentiality provisions and the details of any specific exchanges that have taken place in relation to individual companies or between Ireland and specific jurisdictions cannot be disclosed.
However Revenue has provided the following broad information in relation to exchange of information.
Spontaneous exchanges of information with other jurisdictions in relation to companies.
2013 - 1 exchange
2014 - 2 exchanges
2015 - 3 exchanges
2016 - 28 exchanges
2017 (to August) - 2 exchanges
Since 1 April 2016, Revenue have spontaneously exchanged opinions with jurisdictions that have committed to Action 5 of the OECD’s Base Erosion and Profit Shifting Package and with which Ireland has a legal arrangement. These opinions all relate to companies. In 2016, Revenue exchanged 24 opinions and in 2017 they exchanged 2 opinions. The figure for 2016 included older opinions exchanged under a “lookback” procedure. These are included in the figures above for 2016 and 2017.
Exchanges of data under Council Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation
Revenue has provided the following broad information i.e. by category and year, in relation to the exchange of information with other Member States under the Directive on Administrative Cooperation.
Category
|
Number of records exchanged relating to 2014
|
Number of records exchanged relating to 2015
|
Directors Fees
|
1,763
|
1,764
|
Income from Employment
|
1,564
|
2,045
|
Immovable Properties
|
21,892
|
21,932
|
Life Insurance
|
0
|
0
|
Pensions
|
162
|
361
|
Total
|
25,381
|
26,102
|
Records relating to 2014 were exchanged during 2016 and records relating to 2015 were exchanged during 2017. The records relating to 2016 will be exchanged in 2018. No records relating to life insurance are exchanged as this information is not available in Revenue systems and as a result cannot be exchanged with other Member States.
Other exchange of information
In addition, Revenue exchange information on request and automatically with partner jurisdictions. Automatic exchange of information includes the exchange of financial account information with the USA (under legislation implementing the Foreign Account Tax Compliance Act (FATCA)). Exchange of financial account information under Directive 2014/107/EU (which amends Council Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation) and the OECD Common Reporting Standard is due to take place before the end of September this year.