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Dail Éireann · 2021-06-15

Part of Priority Questions

International Agreements

12 contributions · 3 speakers · 1,220 words

Q51 SF Pearse Doherty to the Minister for Finance

51. Deputy Pearse Doherty asked the Minister for Finance the details of the agreement reached by the G7 and outlined in its communiqué published on 5 June 2021 regarding international tax reform in particular the introduction of a global minimum tax rate of at least 15% for each country; the way it will operate; the impact on the State, its revenues and inward investment offering over medium and long-term horizons; his views on this position; his negotiating objective in relation to same in negotiations at OECD level; and if he will make a statement on the matter. [31854/21]

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Summary of this debate

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Will he update the Dáil on the details of this part of the agreement, the application of the minimum rate and whether that minimum rate will be an effective or headline rate? The Government noted the communiqué of 5 June from the G7 finance ministers, which includes the desire for a global minimum effective tax rate of at least 15%. Pillar 2 in any global minimum effective corporate tax rate will not be decided by the G7 alone, but will be subject to the agreement of 139 countries and jurisdictions under the OECD inclusive framework, including Ireland.

It is our view in Sinn Féin that any agreement reached at the OECD should accommodate an effective corporation tax rate of 12.5%. At this early stage, what is the Department's view of applying a minimum effective tax rate - whatever rate is agreed through the OECD process - across the board?

Built by scoring every sentence in the debate on how distinctive its language is, then quoting the highest-scoring ones back word for word and in the order spoken. Nothing is paraphrased or invented — if a sentence appears here, it was said in the chamber. Drawn from 1,220 words across 12 contributions by 3 speakers.

Most used terms in this debate

How often each word appears across the whole debate, ranked by how distinctive it is to it rather than common to all parliamentary language.

rate 20
oecd 11
communiqué 6
tax 14
minimum 10
global 7
effective 8
grouped 4
companies 8
agreement 8
competitiveness 4
pillar 4

The full debate

All 12 contributions, start to finish, in the order they were made.

SF Pearse Doherty

On 5 June, the G7 reached an agreement on concrete actions, including a suite of tax measures to respond to the increasing globalisation and digitalisation of the world economy. Among the measures agreed was the introduction of a global minimum tax rate of at least 15% for each country. All we have is a published communiqué but the Minister was in the room in his capacity as the president of the Eurogroup. Will he update the Dáil on the details of this part of the agreement, the application of the minimum rate and whether that minimum rate will be an effective or headline rate?

FG Paschal Donohoe

I thank the Deputy for raising this issue and I propose to take Questions Nos. 51 and 53 together.

SF Pearse Doherty

I apologise for interrupting but my understanding is that priority questions cannot be grouped. We sought guidance from the Ceann Comhairle's office and we were told that the Minister's office had been informed of that advice. It is important that we deal with these two matters separately and priority questions cannot be grouped.

FG Paschal Donohoe

I was not informed of that guidance but I am in the hands of the Ceann Comhairle and I am happy to deal with these questions in whatever way he sees fit.

CC Seán Ó Fearghaíl

I take it that Deputy Doherty is correct. I was not aware that priority questions could be grouped with each other. My understanding is that priority questions can be grouped with other non-priority questions.

FG Paschal Donohoe

I am happy to be guided by the Ceann Comhairle and to deal with the questions in the way he sees fit.

CC Seán Ó Fearghaíl

I thank the Minister.

FG Paschal Donohoe

I welcome the opportunity to brief the Dáil on the international tax discussions on foot of the G7 meeting, which I attended in my role as president of the Eurogroup. It is important to stress that the Government believes that it is in everyone’s interest to achieve a sustainable, ambitious and equitable agreement on modernising the framework for international tax to reflect increasing globalisation and digitalisation. Second, it is also important to highlight that reform of the international tax rules has now been part of a process since 2013. Since 2018, Ireland has constructively engaged in the more recent discussions to find a solution at the OECD. This is the subject of the current negotiations which are expected to conclude this year. The OECD is proposing a two-pillar solution. Pillar 1 concerns the allocation of a proportion of taxing rights, while pillar 2 is in regard to a minimum effective tax rate for larger companies.

The Government noted the communiqué of 5 June from the G7 finance ministers, which includes the desire for a global minimum effective tax rate of at least 15%. Deputy Doherty asked a specific question about that meeting. The only document which emerged from the G7 regarding that group's intent was the communiqué to which the Deputy referred. As important as that communiqué is, and it is important, it is also important to stress that it now provides a large input into a process in which 139 countries are now participating. The minimum rate does create challenges for Ireland and other small countries for good reasons. It is my intention to continue to make the case for an agreement to accommodate Ireland’s low but substantial 12.5% rate.

SF Pearse Doherty

The Minister knows Sinn Féin supports the OECD base erosion and profit shifting, BEPS, process. The announcement by the G7 of its intention to establish a global minimum effective corporation tax rate of 15% was the view of that group regarding where pillar 2 of that process should land, but there are other views. Pillar 2 in any global minimum effective corporate tax rate will not be decided by the G7 alone, but will be subject to the agreement of 139 countries and jurisdictions under the OECD inclusive framework, including Ireland. It is clear that this process has momentum and that the members of the G7 and the broader OECD are already seeking carve-outs and exemptions for strategic industries and economies under pillars 1 and 2. It is also clear that they will doggedly pursue their own national interests in that process, as is the right of those countries.

We must pursue an outcome that is fair and that works for all countries and jurisdictions party to the process, including Ireland. It is our view in Sinn Féin that any agreement reached at the OECD should accommodate an effective corporation tax rate of 12.5%. What strategy is the Minister going to adopt ahead of the G20 and OECD talks? Does he believe that there is any support internationally for this approach?

FG Paschal Donohoe

The strategy we will be implementing is a continuation of what we have done to date. First, in bilateral engagements with many Ministers, including the US Secretary of the Treasury, Ms Yellen, we will continue to make the case for legitimate tax competition within certain boundaries, with a recognition of the role that our rate plays for our country. Second, inside the OECD process that will be intensifying, we will continue to make the case for that rate and will outline our broader views in relation to other elements of the OECD process. We will do that across the coming three to four weeks. There will be a further OECD meeting in July and another will take place in October. In each of those engagements and in the preceding weeks, we will make the case for our rate and for the competitiveness of small countries.

SF Pearse Doherty

As the Minister knows, the agreement reached by the G7, which may not be the final agreement, only applies to certain companies. Even if it is applied, it will not affect all companies or foreign direct investment, FDI, companies here in Ireland. At this early stage, what is the Department's view of applying a minimum effective tax rate - whatever rate is agreed through the OECD process - across the board? Is it the Department's view that there should be a rate specific to those companies that fall into the net of having annual turnover of €750 million or more? Is it now time to look at our competitiveness in other areas outside of tax? The housing crisis, for example, has been called out by the National Competitiveness Council, NCC, repeatedly in this regard. Education, research and development, infrastructure and quality of life issues such as childcare and housing are all crucial and will be even more important in the future, given the changes taking place internationally. Is the Department considering committing extra resources and revenue to those areas?

FG Paschal Donohoe

Deputy Doherty first asked if I anticipate that the potential global minimum effective tax rate will cover more companies than are currently encompassed in the G7 communiqué. That is a possibility but the case that we will be making is that regardless of where the rate ends up, if a rate is agreed at a global level, it should only apply to the very largest companies. As Deputy Doherty has already noted, the communiqué as it currently stands only applies to companies generating more than three quarters of a billion euro of global turnover.

The Government has been increasing investment in other areas that are very important to our competitiveness. Taxation is part of our competitive model but there are many different elements in that model.