Dáil Éireann Debate, Tuesday - 15 January 2019
243. Deputy Joan Burton asked the Minister for Finance the number of claims made by companies for correlative adjustments in each of the years 2010 to 2018; the number of claims for correlative adjustment conceded by the Revenue Commissioners; the value of the tax involved in those claims; and the amount of tax involved in each of the three largest cases in respect of the number of claims made in these years by industry and the other country involved. [1494/19]
View answer244. Deputy Joan Burton asked the Minister for Finance the estimated cost of refunds arising from correlative adjustments made in 2017 and 2018. [1496/19]
View answer245. Deputy Joan Burton asked the Minister for Finance the tax at risk in respect of all open claims for correlative adjustments; and if he will make a statement on the matter. [1497/19]
View answerI propose to take Questions Nos. 243 to 245, inclusive, together.
I would clarify that correlative relief claims may be more appropriately described as potential tax refunds which Revenue may be required to make in accordance with our tax treaty obligations, as opposed to tax at risk.
Regarding open claims for correlative adjustments, I am advised by Revenue that as at 30 September 2018, the latest period for which relevant data has been compiled, approximately €271 million in tax was the subject of open correlative relief claims.
Regarding 2017 and 2018 claims, correlative relief with a tax value of approximately €26 million has been granted as at 30 September 2018.
The table below includes the number of correlative relief claims made by companies for each of the years 2010 to 30 September 2018, together with the number of claims where correlative relief was granted and the tax value of relief granted.
|
Year of claim |
Number of claims received |
Tax value of relief granted * |
|
2010 |
16 |
€89.7m |
|
2011 |
8 |
€40.9m |
|
2012 |
13 |
€34.2m |
|
2013 |
10 |
€9.2m |
|
2014 |
12 |
€3.8m |
|
2015 |
14 |
€9.0m |
|
2016 |
9 |
€0.0m |
|
2017 |
8 |
€15.0m |
|
2018 |
10 |
€0.0m |
* Correlative 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.
I am advised by Revenue that, having regard to their obligation to observe confidentiality in relation to the tax affairs of taxpayers or small groups of taxpayers, they are not in a position to provide the information requested by the Deputy in relation to the numbers of claims where correlative relief was granted, the amount of tax involved in the three largest cases or the industry or the adjusting country with respect to those cases.
Finally, it is to be noted that claim numbers and amount of tax relief granted as a result of corresponding adjustments agreed between Revenue and the tax authorities of other countries under the Mutual Agreement Procedures provided for in Double Tax Treaties are not included in the above figures.
