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Revenue Commissioners Reports

Dáil Éireann Debate, Tuesday - 29 May 2018

Tuesday, 29 May 2018

Ceisteanna (197)

Joan Burton

Ceist:

197. Deputy Joan Burton asked the Minister for Finance if he will request the Revenue Commissioners to publish an annual analysis of tax at risk, including, but not limited to, the number and amount of tax in dispute under correlative adjustment mutual agreement procedures, MAPs, tax appeals and so on, to be included in the office's annual report; and if he will make a statement on the matter. [23484/18]

Amharc ar fhreagra

Freagraí scríofa

As the Deputy is aware Revenue publish comprehensive analysis and statistics in conjunction with the Annual Report. I know that Revenue is committed to publishing data to facilitate public debate subject to the constraints of taxpayer confidentiality.

I am advised by Revenue that at 31 March 2018 there were 30 open Mutual Agreement Procedure (‘MAP’) cases and 39 open correlative relief cases which relate to adjustments raised by tax authorities in Tax Treaty partner countries in respect of transfer-pricing or the attribution of profits to permanent establishments.

MAP cases involve bilateral negotiations with tax authorities in other jurisdictions while correlative relief cases are dealt with on a unilateral basis. Some of the MAP cases are at an early stage and Revenue has not yet received sufficient information to estimate the potential Irish tax relief that could result from closing the cases.

For those MAP cases where the potential relief is known, the maximum aggregate tax value of the relief could amount to €250m. The maximum aggregate tax value of the correlative relief adjustments could amount to €251m.

While the aggregate values are based on granting relief for the full foreign adjustments, the total relief ultimately granted in MAP cases is likely to be less, as a result of the withdrawal or reduction of the foreign adjustments concerned on the conclusion of the MAP negotiations. Similarly, for correlative relief cases, the total relief ultimately granted is likely to be less following technical reviews of the claims by Revenue.

In regard to appeals, the Tax Appeals Commission (TAC) is an independent statutory body responsible for receiving, processing, adjudicating and determining appeals. As the TAC is now the competent body for the management of appeals, I consider that it is appropriate that it be the primary source for appeals statistics.  

While Revenue maintains statistics on appeals, for various reasons these will not necessarily correspond with those provided by the TAC. For example, there may be time lags in the notification of new appeals by the TAC to Revenue and also time lags in the closure of appeals by the TAC following settlement of an appeal by agreement between Revenue and the appellant.

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