Dáil Éireann Debate, Tuesday - 7 July 2015
120. Deputy Derek Nolan asked the Minister for Finance the level of engagement on the exchange of tax information between the Revenue Commissioners and foreign tax authorities; the improvements that have occurred; and if he will make a statement on the matter. [27113/15]
Amharc ar fhreagra121. Deputy Derek Nolan asked the Minister for Finance his views on the introduction of full country-by-country reporting by multinational corporations; if Ireland is advocating in favour of such a provisions at the international level; and if he will make a statement on the matter. [27114/15]
Amharc ar fhreagraI propose to take Questions Nos. 120 and 121 together.
Revenue is fully and actively engaged in the exchange of information between Revenue and the tax authorities of jurisdictions with whom we have a legal basis for the exchange of information. In 2014, Revenue received 515 requests for exchange of information in respect of direct taxes and VAT from other jurisdictions and made 295 requests to other jurisdictions.
Ireland's level of engagement in exchange of information on request is extending in scope by reference to the increasing coverage of our Tax Treaty and Tax Information Exchange Agreement network and also by our ratification in 2014 of the Council of Europe/OECD Multilateral Convention on Mutual Assistance in addition to exchange of information under the EU Directive on Administrative Cooperation.
This cooperation is set to greatly expand through the automatic exchange of financial account information under Ireland's intergovernmental agreement with the United States in relation to the US FATCA legislation and the related OECD and EU developments providing for Common Reporting Systems (CRS) for such information. In relation to CRS reporting, I have committed Ireland to being one of the "early adopter" countries that will commence the automatic exchange of financial account information in September 2017.
Ireland has also been supportive of Country by Country Reporting and my Department has signalled that support in my Department's 2013 International Tax Strategy document. More recently, we have taken an active role in the development of an internationally coordinated approach to CbCR as part of our commitment to the OECD/G20 BEPS project. In supporting the agreed approach that has been set out in detail on foot of the BEPS project work, we are conscious that successful implementation will require the coordinated participation of a wide range of countries.
The proposed rules on CbCR will require multinational corporations (MNC's), with consolidated annual group revenue of €750 million or more, to file the CbC report annually in the country in which the parent entity of the MNC is resident. The information required is the amount of revenue, profit before tax, tax paid and accrued for each tax jurisdiction in which the MNC does business. It also requires MNC's to report their total employment, capital, retained earnings and tangible assets in each tax jurisdiction. Finally, it requires MNC's to identify each entity within the group doing business in a particular tax jurisdiction and to provide an indication of the business activities each entity engages in.
