I propose to take Questions Nos. 123 to 125, inclusive, together.
Regarding open claims for correlative adjustments, I am informed by Revenue that approximately €242 million in tax is the subject of open correlative relief claims. 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 2017 and 2018 claims, correlative relief with a tax value of approximately €24 million has been granted to date in 2017. It should be noted that, as the processing of these claims takes place throughout Revenue’s four Regions and in the Large Cases Division, some completed claims may not have been fully recorded at the time of preparing this reply.
I am informed by Revenue that it is not possible to estimate the likely tax cost of refunds that may be made in the remaining months of 2017 or in 2018 given the complexity of correlative relief claims and the detailed work which must be undertaken to verify whether the granting of correlative relief is appropriate.
The table includes the number of correlative relief claims made by companies for each of the years 2008 to 2016 and to date in 2017, together with the number of claims where correlative relief was granted and the tax value of relief granted.
|
Year of claim
|
No. of claims received
|
No. of these claims where relief granted
|
Tax value of relief granted *
|
|
2008
|
15
|
12 (3 claims were withdrawn)
|
€319.2m
|
|
2009
|
13
|
11 (1 claim was withdrawn and 1 claim is still open)
|
€83.1m
|
|
2010
|
16
|
15 (1 claim was withdrawn)
|
€89.7m
|
|
2011
|
8
|
5 (1 claim was withdrawn and 2 claims are still open)
|
€40.9m
|
|
2012
|
13
|
9 (1 claim was withdrawn, 2 claims were not allowed and 1 is still open)
|
€34.2m
|
|
2013
|
10
|
5 (2 claims were withdrawn and 3 claims are still open)
|
€9.2m
|
|
2014
|
12
|
4 (1 claim was not allowed and 7 claims are still open)
|
€3.8m
|
|
2015
|
14
|
4 (2 claims were withdrawn and 8 claims are still open)
|
€8.0m
|
|
2016
|
9
|
0 (9 claims are still open)
|
€0.0m
|
|
2017**
|
3
|
1 (2 claims are still open)
|
***
|
* 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.
** 2017 claims may be understated as a result of claims for correlative relief submitted since June 2017 which are not yet reflected in the records maintained by Revenue.
*** As there is only one case involved, publication of the amount of tax relief granted is not considered appropriate as it could lead to identification of the company.
The amount of tax involved in the three largest cases is approximately €372 million. I am informed by Revenue that their obligation to observe confidentiality in relation to the tax affairs of taxpayers or small groups of taxpayers precludes them from providing information requested by the Deputy in relation to the industry or the adjusting country with respect to those three 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.
