Chartered Accountants House
47 – 49 Pearse Street
Mr Michael Noonan TO
Minister for Finance
Government Buildings
Merrion Square
Dublin 2

29 May 2013

Dear Minister

Corporation Tax and Reputational Issues

Having followed and participated in the debate on Ireland's Corporation Tax status in recent days, prompted by the US Senate subcommittee citation of the tax arrangements of multinational companies, we share the concern that our international reputation could have been prejudiced. It is very important to ensure, both at home and abroad, that Ireland's position as a straightforward broker in the network of international tax rules is fully explained. The clarification this week by Mr Cook, the Chief Executive Officer of Apple Corporation that his company had no special deal with our Government is very helpful.

Equally however, we feel that the action to be taken at this stage should be limited to clarification and explanation. It is not immediately evident to us how any unilateral change, say to our corporate residency tax rules, would repair any reputational damage done. Rather, it might send a signal that Ireland considers there is a problem with existing tax rules. Further, it would add another item on the list of matters to be explained in the international arena and thus would complicate the message.

The broader tax perspective is of course that the controversy diverts attention from the needs of our domestic economy. Your last Budget identified 10 tax measures towards improvement in the indigenous sector, and I hope that progress on these will not be hampered by reason of the focus on our Foreign Direct Investment incentives.

I have asked colleagues here to take all appropriate steps towards clarifying and explaining Ireland's position on our corporate tax regime, both at home and abroad.

Yours sincerely

Brendan Lenihan

Chairman, CCAB-I

Source: Chartered Accountants Ireland. www.charteredaccountants.ie