Corporate Tax Compliance

Dáil Éireann Debate, Wednesday - 31 January 2018

Wednesday, 31 January 2018

Ceisteanna (132, 133, 134, 135, 136, 137, 138)

Joan Burton

Ceist:

132. Deputy Joan Burton asked the Minister for Finance the number of companies that have applied for section 110 status in each of the years 2014 to 2017; and if he will make a statement on the matter. [4705/18]

Joan Burton

Ceist:

133. Deputy Joan Burton asked the Minister for Finance the number of section 110 companies that submitted tax returns for each of the years 2010 to 2016; and if he will make a statement on the matter. [4706/18]

Joan Burton

Ceist:

134. Deputy Joan Burton asked the Minister for Finance the number of audits by type, that is, single tax head, comprehensive and single issue carried out by the Revenue Commissioners on companies with section 110 status in 2016 and 2017 respectively; and if he will make a statement on the matter. [4707/18]

Joan Burton

Ceist:

135. Deputy Joan Burton asked the Minister for Finance the number and value of VAT repayments issued to section 110 companies by the Revenue Commissioners in each of the years 2015, 2016 and 2017; and if he will make a statement on the matter. [4708/18]

Joan Burton

Ceist:

136. Deputy Joan Burton asked the Minister for Finance the number of section 110 companies which were approved in each of the years 2005 to 2017 and to date in 2018, which have notified the Revenue Commissioners that they are no longer trading, in tabular form; and if he will make a statement on the matter. [4709/18]

Joan Burton

Ceist:

137. Deputy Joan Burton asked the Minister for Finance the estimated assets under management in section 110 companies in 2016 and 2017; and if he will make a statement on the matter. [4710/18]

Joan Burton

Ceist:

138. Deputy Joan Burton asked the Minister for Finance for the number of section 110 companies which owned Irish assets in each of the years 2014, 2015 and 2016; and if he will make a statement on the matter. [4711/18]

Freagraí scríofa

Minister for Finance

I propose to take Questions Nos. 132 to 138, inclusive, together.

In relation to Question No. 132 and Question No. 136, I am informed by Revenue that between 1 January 2005 and 31 December 2017 a total of 3,893 companies had notified Revenue that they were qualifying companies for the purposes of section 110 Taxes Consolidation Act 1997. 762 of these company's corporation tax registrations had been ceased up until 3 June 2017.  The breakdown by year of notification is as follows:

Year	Number of notifications   received	Number  of tax registrations ceased*
2005	167	80
2006	257	97
2007	435	216
2008	242	115
2009	140	73
2010	137	43
2011	159	39
2012	130	15
2013	223	23
2014	344	42
2015	423	12
2016	477	6
2017	759	1
Total	3,893	762

*Figures in relation to the number of tax registrations ceased is only available up until 3 June 2017.

In relation to Question No. 133, I am informed by the Revenue that, as for all taxpayers,  companies that have notified Revenue that they are a “qualifying company” for the purposes of section 110 Tax Consolidation Act 1997 and have a “live”  corporation tax registration are required to submit corporation tax returns within 9 months of the year-end.  As of Friday 26 January 2017, 2,545 section 110 companies have submitted tax returns for 2016.   Information relating to the years 2010 to 2015 is recorded by taxpayer rather than by taxpayer type and it is not possible to distinguish between section 110 companies and other taxpayers.  Therefore information relating to 2010 to 2015 is not readily available. 

In relation to Question No. 134, I am informed by the Revenue that the number of audits carried out on companies that have notified Revenue that they are qualifying companies for the purposes of section 110 Taxes Consolidation Act 1997 during 2016 and 2017 is as follows:

Comprehensive	3
Multi tax head	1
Single tax head	1
Total	5

As for all taxpayers, Section 110 companies are selected for compliance interventions based on the presence of various risk indicators in accordance with the “Code of Practice for Revenue Audit and other Compliance Interventions”.  The number of Aspect Queries completed on section 110 companies during the years ended 2016 and 2017 are:

	2016	2017	Total
Aspect Query	348	203	551

In relation to Question No. 135, I am informed by Revenue that the number and value of VAT repayments issued to section 110 companies by Revenue in each of the years 2015, 2016 and 2017 is as follows:

Year	Value of VAT   Repayments € millions	No of Repayments
2015	3.4	892
2016	8.1	1,042
2017	10.9	1,338

In relation to Question Nos. 137 and 138, I am advised by Revenue that there  is no requirement for information regarding the value or type  of “qualifying asset” (within the meaning of section 110 Taxes Consolidation Act 1997)  held by section 110 companies to be included on the corporation tax returns submitted by taxpayers, Revenue is not in a position to provide the information requested regarding estimated assets under management or the number of section 110 companies which owned Irish assets. Irish resident section 110 companies are obliged to report quarterly data to the Central Bank under section 18 of the Central Bank Act 1971. The data reported includes details of the assets held by section 110 companies. This data can be found on the Central Bank website.

www.centralbank.ie/statistics/data-and-analysis/other-financial-sector-statistics/financial-vehicle-corporations.