112 Deputy Olivia Mitchell asked the Minister for Finance if his attention has been drawn to the extent of challenges by US Internal Revenue to pricing arrangements between Irish based affiliates of US corporations and related corporations based in the US; if his attention has been drawn to the fact that successful challenges to pricing arrangements in these circumstances can result in a refund or downward adjustment having to be made by the Revenue Commissioners of corporation tax already paid on profits reported under Article 9 of the taxation treaty between the two countries; the number of such pricing challenges made by US Internal Revenue for the years 2005, 2006, 2007 and 2008; the number of cases finalised to date in 2009; the yearly amounts of tax repaid or agreed to be repaid for each year or where applicable, downward adjustments of Irish tax; and if he will make a statement on the matter. [46210/09]

Summary

112 Deputy Olivia Mitchell asked the Minister for Finance if his attention has been drawn to the extent of challenges by US Internal Revenue to pricing arrangements between Irish based affiliates of US corporations and related corporations based in the US; if his attention has been drawn to the fact that successful challenges to pricing arrangements in these circumstances can result in a refund or downward adjustment having to be made by the Revenue Commissioners of corporation tax already paid on profits reported under Article 9 of the taxation treaty between the two countries; the number of such pricing challenges made by US Internal Revenue for the years 2005, 2006, 2007 and 2008; the number of cases finalised to date in 2009; the yearly amounts of tax repaid or agreed to be repaid for each year or where applicable, downward adjustments of Irish tax; and if he will make a statement on the matter. [46210/09]

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• Tax Code.

  xml · EN · 9 December 2009

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