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.