Corporation Tax - Northern Ireland Affairs Committee Contents


Examination of Witnesses (Questions 1-65)

Q1 Chair: Minister, thank you very much for joining us. We are small in number; we are competing with some elections, which I think are taking place in Northern Ireland, so we do not have our whole team here. We eagerly anticipate this particular discussion. It is probably going to be the last evidence session we take before we start to put our report together on corporation tax and enterprise zones, so thank you very much for joining us. I wonder if I could start with a general question: perhaps you could give us the background to the Treasury thinking on this whole issue, particularly with regard to any possibility of a change in corporation tax for Northern Ireland.

David Gauke: Thank you, Mr Chairman. First of all, could I introduce Mike Williams from the Treasury, who will correct me as and when I make various factual errors over the course of this afternoon? It is a great pleasure to be here and to have the opportunity to discuss this particular matter, particularly focusing on corporation tax for Northern Ireland.

The position, as you will be aware, is that Owen Paterson, the Secretary of State for Northern Ireland, has long been an advocate of looking at this area of Northern Ireland being able to vary its rate of corporation tax. It is the case that Northern Ireland is heavily dependent upon the public sector; it has a much smaller private sector than the rest of the United Kingdom. It is wrestling with some of the legacy issues following the Troubles and does have a land border with the Republic of Ireland, which of course has a corporation tax rate significantly lower than that of the UK.

  In that context, as set out in the coalition agreement, we are looking, as a Government, at the options that may be available to rebalance the Northern Ireland economy. In particular we are looking at the option of devolving corporation tax to the Northern Ireland executive in a way so that it is able to, through its choice and through its decisions, rebalance the economy to have a more competitive corporation tax rate, with the intention of attracting additional investment to Northern Ireland. Of course, there are various practical points that need to be addressed and those are set out within the consultation paper. I am keen to learn the views of the Committee in due course on some of the issues that need to be addressed with some of the practical points about administration—how we ensure that this can be done in a way that does not cause a great deal of tax avoidance or does not impose unnecessary burdens on businesses that conduct activities in both Northern Ireland and the rest of the UK.

However, I am very pleased that we were able to complete that paper with strong cooperation, involving the Treasury, the Northern Ireland Office and the Northern Ireland Executive. I was very pleased to attend the launch on 24 March with representatives from the five leading parties in Northern Ireland, where it struck me that there was considerable appetite to explore this area. We are keen to facilitate that, have a debate and we may well be able to progress this.

Q2 Jack Lopresti: The Government is obviously committed to reducing corporation tax until it reaches 23% in the next couple of years. Have you forecast what these reductions will mean for the revenue we are expected to get back across the UK once these reductions have taken place?

David Gauke: You are absolutely right; we announced reductions in the June 2010 Budget from 28% to 24% at 1% a year. Then in the March 2011 Budget we announced an additional cut of one penny, meaning we are going from 28% to 26% now and moving on to 23%. There are clearly costs involved in the short term. I would have to remind myself of the overall total cost of those cuts, but clearly the numbers that have been produced by the Office of Budget Responsibility demonstrate that there is a fiscal cost for each cut, although we believe that economically this is a good long-term position that will attract additional investment to the UK.

Q3 Jack Lopresti: As some of us obviously focused with Northern Ireland think that reduction in the rate there will have good material benefits, why don't we just look at the rate across the whole UK if it is such a good idea to reduce it in Northern Ireland?

David Gauke: I think the first point to acknowledge is that there is a particular case with Northern Ireland; the need to do more to stimulate the private sector there to increase investment is even stronger than it is across the UK as a whole. The cost of reducing corporation tax to 12.5% across the UK would be very considerable. Indeed, we get something in the region of £40 billion a year in the UK through corporation tax. Clearly, we are in circumstances where the deficit is very large and we have limited room for manoeuvre, so whatever the long-term arguments we probably cannot afford to do that. However, given the unique circumstances of Northern Ireland, there is an argument—and this is something that the Northern Ireland Executive and Northern Ireland Assembly would need to determine—for pursuing this policy there.

Q4 Oliver Colvile: First of all, thank you very much indeed for coming to see us and giving up your time. Whilst I can quite understand Northern Ireland has a very specific case, my constituency, Plymouth, Sutton and Devonport, has 38% of its employment group dependent upon the public sector as well. That is not including those people who work in the dockyard, which is of course to do with defence contracts so that could ultimately change that. Is there any chance at all that you might potentially look at other parts of the United Kingdom that might have the same kind of problems as Northern Ireland, and see as to whether or not you might look at altering the corporation tax in those individual areas? Is this just solely for Northern Ireland, or might you look at those of us who represent seats that also have high problems of trying to rebalance the economy?

David Gauke: I think there would be significant difficulties if we tried to use corporation tax in a very targeted way in specific areas, simply because one would see considerable economic distortions, and monitoring and administering corporation tax in that way would be quite difficult. As I say, Northern Ireland has a land border with the Republic of Ireland but does not have a land border with any other part of the UK, so is better placed to do that.

That is not to say that we should not be looking to find ways of helping those parts of the UK heavily dependent upon the public sector. Of course, as you will be aware, one of our policies is the national insurance contributions holiday in those regions and nations of the UK outside the greater south-east for start-up businesses. I know the intention is not to talk about that today, but we have not had the numbers taking up that NICs holiday that we would like. However, there are steps that the Government is taking to try to encourage the private sector in those areas where it is not as strong as it might be. As far as corporation tax is concerned, though, I think there is a special case for Northern Ireland. Let's not forget it is a fairly bold policy to be reducing corporation tax from 28% to 23%, which I hope the whole of the UK will benefit from.

Q5 Ian Paisley: Minister, if I could bring you back to the Northern Ireland Affairs Committee instead of the Portsmouth Affairs Committee.

Oliver Colvile: Plymouth, actually, and we are not 20 minutes away from Bristol either.

Ian Paisley: But there is reported tension between Her Majesty's Treasury and the Northern Ireland Office on this point of varying the corporation tax to a region of the United Kingdom. In your opening comments you used very interesting language. You said that there is an "appetite to explore this differential", which does not sound like a done deal to me. Indeed, I understand there is a consultation out, but certainly the press and the fair wind that Her Majesty's Government is giving to this is that this is a done deal: this needs to be done and needs to be done with expedition, and I agree with that point of view, I might add—I am very keen on that. But could you tell me, and could you assure this Committee, that Her Majesty's Treasury is fully bought in to this and is committed to this, and that the reports of tension are nothing more than just reports of tension; there is no substance to that?

David Gauke: I would not describe the relationship as one of tension. The Secretary of State for Northern Ireland and I have worked very closely on this. You ask, "Is this a done deal?" We have been very clear that this is a consultation and that final decisions are to be made, but what I can say is that if the Treasury wanted just to kill this idea, we would have done so. The position that we are in is that we have published this paper; I was there for the launch in Lisburn on the day after the Budget. I think there is a lot to be said for this particular policy.

It is important, however, that we go into this with our eyes open, that we explore all the pros and all the cons, that we get that debate developed, we draw out the issues and then can make a very informed decision. It has been clear all the way through that this is a consultation and that the final decisions will be made in light of the response to the consultation. My view is that I want to encourage as much engagement as possible with this consultation, and I think we have been very clear that we want to hear the voices of business groups and others who have something to say in this debate.

Q6 Gavin Williamson: If you were, for example, not the hon. Member for South West Hertfordshire but the hon. Member for South West Antrim, would you be wanting to have this reduction in corporation tax to balance off the issues in terms of taking off the block grant? Would it be something that you would be pushing for?

David Gauke: It is a very good question, and I suspect I would. I think we need to understand all the issues. We need to understand, for example, the impact on a business that is located both in the mainland and Northern Ireland to understand what the practical issues are that will arise and whether there is an additional administrative burden. However, the arguments that have been put to us, as a Government, by a number of organisations and people—that Northern Ireland needs to rebalance its economy, needs a stronger private sector and needs more investment in—all raise important points, and ones that may well be addressed by the proposal to give greater flexibility on corporation tax to the Northern Ireland executive. So, as someone who also realises there is a lot of academic criticism of corporation tax as a tax of being more distortive, perhaps, than some of the other major taxes, I would certainly want to give this a fair wind.

Q7 Mel Stride: Welcome to the Committee; thank you for coming. The paper seems to reflect much of the evidence we have heard on the Committee, in terms of stressing that corporation tax reductions alone are unlikely to have the kind of impact that perhaps we are looking for. In the Irish Republic, as you will be aware, thin capitalisation and perhaps a lack of regulation of transfer pricing, and aspects like that, seem to have been important in terms of attracting FDI. I would just value your comments on that aspect, because that is unlikely to be something that is going to be available to Northern Ireland in that particular context.

David Gauke: I think you raise a very good point. I do not think anyone should believe that there is one silver bullet here, and if you just cut corporation tax, everything else falls into place. There are many other issues where Northern Ireland can and should look to make itself more attractive. For example, I know there is a lot of work going on in the area of planning. You raise a very interesting point about the Republic of Ireland and, for example, its treatment of foreign profits. Undoubtedly that is one of the things that the Republic of Ireland has had as a competitive advantage in for a number of years.

It was largely in that area why we saw a number of businesses re-domicile out of the UK to the Republic of Ireland; whereas they had a much looser arrangement, we had a controlled foreign companies regime that was seen as being disproportionate and oppressive. Of course, as you all know, we have announced some significant changes to that regime that appear to have been widely welcomed. As a consequence, we hear talk from the likes of WPP about returning to the UK.

  Is this just about corporation tax? Does it solve everything? You are absolutely right: no it does not. It is the case though, if we are looking at multinational businesses with a lot of profits made overseas, that the UK as a whole, including of course Northern Ireland, will have a much more competitive regime in the future than they have had over recent years.

Q8 Mel Stride: In terms of tax reductions and the lessons to learn from the Republic of Ireland, one of lessons seems to be that you need to have these tax reductions in place for a long time and demonstrate to the marketplace that they are going to be low for a long period rather than a short in-and-out situation. Could you comment on what you think the implications of that factor might be in the case of Northern Ireland?

David Gauke: Again, that is a very good point. I talk to a lot of businesses with the intention of making the case that the UK is a very good place in which to be based, and one of the messages that businesses do give us is that they need to look at the long term; they need to look at what the position is going to be not just over two or three years but over five, 10, 15 years. It strikes me in the context of Northern Ireland that a more competitive corporation tax level will be more effective if there is a consensus within the Northern Irish parties, across the political groupings, that that is the right direction to go in, and there is a determination to maintain it—that this is not something that we will try for a couple of years and abandon if it does not work. That would be my observation. This is more likely to be effective if there is real willingness to stick it out.

Q9 Lady Hermon: Minister, it is very welcome to see you here this afternoon. May I just ask you to clarify one slight point before I go on about a question that you have just answered? This is just quoting from the Treasury paper Rebalancing the Northern Ireland Economy, and I am intrigued by the last line, paragraph 4.11: "it is necessary to be cautious"—and this is the Treasury warning everyone—"in assuming that a lower corporation tax rate would have the same effect in Northern Ireland as it had in the Republic" of Ireland. Why did the Treasury think when they were publishing this paper that it was necessary—not "desirable" but "necessary"—to be cautious?

David Gauke: The implication of what it is saying is that there are differences between the Republic of Ireland and Northern Ireland. It comes back to the comments that Mr Stride just made, that one has to look at the Republic of Ireland tax system more broadly and not just the rate to fully understand the impact of their tax system upon their economy. Unless you replicate that exactly, one could say that there could be some divergence between what happens in the Republic of Ireland and Northern Ireland. I think all it is saying is that they are different circumstances; there might be different consequences of following a policy of, for example, a 12.5% rate of corporation tax, but that is not to undermine the overall case for a lower rate of corporation tax.

Q10 Lady Hermon: As a Treasury Minister, could you just advise the Committee: at the present time, how many companies in Northern Ireland actually pay corporation tax? The Secretary of State was unable to tell us at the last session.

David Gauke: In light of your earlier question to the Secretary of State, we dug out the numbers. In recent years it has varied; between 50% and 63% of companies in Northern Ireland pay corporation tax.

Q11 Lady Hermon: And translate that into figures if you would, please. That would be very helpful. Percentages are all very well and good, but percentages of what? What is the total figure?

David Gauke: The total number of companies within Northern Ireland—there is a number of 60,000 that is springing to my head, but I do not know if that is correct. I suspect I will find inspiration in the—

Lady Hermon: Mr Williams will probably look up the answer.

David Gauke: It might be a bit unfair on Mr Williams, but I suspect inspiration might spring to me shortly as to how many companies there are in Northern Ireland. We may come back to that a little later in the discussion.

Chair: We did want to press on the amount of money raised through corporation tax.

Q12 Ian Paisley: Yes, that is a slightly different matter. The number of companies is one thing, who actually pay, and the level they pay. It is the amount of money that is actually raised. You currently have an estimate of £465 million for the 2009-10 financial year and you have a guesstimate that by 2015 that could be £685 million. If those figures are out by £100 million or even £50 million, the difference that would make to me in saying, "Well, let's phase this in at a particular speed," would be considerable. I would have thought it was basic housekeeping that the Northern Ireland Executive and politicians on this Committee should know the accurate figure of the money that HM Treasury raises by the tax take in Northern Ireland and then we could do that calculation. Can you give us that figure?

David Gauke: The first point to make—and I know that this issue came up in the questions to the Secretary of State—is that as a matter of course HMRC does not identify which part of the United Kingdom corporation tax revenue comes from because it does not have to. At present if it is from the UK, it is from the UK, and one does not need to attribute it to one part or the other of the UK.

The methodology that we have used in the consultation paper in coming up with the 1.5% of corporation tax revenues, which is the basis of the numbers we have used, is looking at those companies whose head office has a post code within Northern Ireland,[1] and attributing those profits to those companies and aggregating them. That gives us the number. For most years, if you look at it from 2003-04 to 2007-08, it was in the range of 1.3% to 1.6% of the overall corporation tax take. The following year it was lower, but we think that was due to the impact of the recession. Presumably further evidence will emerge as time moves on.

  That is how we got to that particular calculation. It might not be wholly accurate; it does not take into account, for example, profits arising from branches—from companies that might be located in the mainland but have a branch in Northern Ireland. Those are profits that should be attributed to Northern Ireland but are, under this methodology, to the mainland or vice versa. So that is how we have worked out the numbers for this calculation. Then we use the overall OBR assessment of what corporation tax revenues will be over future years and, as I say, that is how those numbers were calculated.

Q13 Ian Paisley: Are you doing us a favour by that black art calculation, or are you doing Treasury a favour by that particular method of calculation? It is just, you can appreciate, you would buy into this all the quicker if you knew the accurate figures one way or the other.

David Gauke: We try—

Q14 Ian Paisley: Maybe you are doing us a huge favour in saying, "Well, actually there is a lot of profit we are discounting here."

David Gauke: We are not trying to do anybody a favour as such; we are trying to get the accurate number.

Q15 Ian Paisley: So you are doing the Treasury a favour then.

David Gauke: So we are trying to get the accurate number. Of course, if we go down this route then clearly we are going to have to develop the methodology. It is quite interesting looking at the process with Scotland and the Calman Commission, for example, where we are moving to part of the income tax revenue being under the control of Scotland and the Scottish Government. In those circumstances, we are going to run a transitional period so that we can get those numbers as accurate as possible.

Q16 Ian Paisley: How long do you think that will take?

David Gauke: I think the transitional period is a couple of years.

Q17 Ian Paisley: It is just that this consultation expires on 24 June. Do you imagine that we would have a more accurate figure than the guesstimates in front of us before then or would you be doing that immediately after?

David Gauke: That would be afterwards.

Q18 Ian Paisley: And how long would that calculation take?

David Gauke: The numbers that we have are best estimates, and I explained the methodology. That is the inherent challenge here, given that HMRC does not need to and therefore does not calculate where the profits come from. My view is that if we go down this route, in the years ahead as we move towards implementing this and, indeed, even after we implement this, where we will have much better knowledge—after starting to implement it we would be able to see exactly where the profits were coming from—we could start to adjust our calculations—

Ian Paisley: It sounds like a permanent negotiation.

David Gauke: —on the basis of the evidence as it develops.

Q19 Ian Paisley: Would it be a permanent negotiation year on year then, in terms of how much tax take would be taken back?

David Gauke: I do not see this as a matter of negotiation. I would see this as a matter of constantly refining the methodology to have as accurate as possible an assessment of the revenue that is coming from Northern Ireland as compared with the rest of the United Kingdom.

Mike Williams: It might be worth mentioning as well that, of the four big sources of Government revenue, corporation tax is pretty clearly the hardest to predict. It varies more; it is harder to make a forecast three years into the future that will prove accurate. Whereas, if you are forecasting income tax, national insurance or VAT, in the nature of things you are not going to get it exactly right, but you are more likely to get it right than you would tend to get right with corporation tax profits.

Q20 Chair: I think that is accepted, but I find it unusual that the present figures are not known. You can look at statistics across the United Kingdom; you can analyse everything to the nth degree. I find it difficult to understand why something as big as this, the Treasury does not know, give or take, how much—

David Gauke: Can I give you an example?

Chair: I have a lot of sympathy with the Secretary of State's position on this. He quotes the subvention that Northern Ireland gets, but he can only do that to a certain degree of accuracy if this figure is not known.

David Gauke: Let me give you an example: if we have a business such as a supermarket chain that operates throughout the United Kingdom, including a number of stores in Northern Ireland, we do not require it to break down its profits into those made in Scotland, Wales, Northern Ireland and England, or even break England down into the various regions. We just get the number for the profits. We have never needed to break it down, and so that would be an imposition on businesses—an additional burden—maybe not a massive one but nonetheless an additional burden. It is therefore one that HMRC has never asked for businesses that operate throughout the United Kingdom.

One of the challenges if we do go down this route is that of course we will be breaking that up to some extent; we will be requiring businesses to identify which of their profits relate to Northern Ireland and which of their profits relate to elsewhere in the United Kingdom. That is one of the disadvantages of the policy.

Q21 Chair: You would have to do that to satisfy the European rules?

David Gauke: Yes, indirectly I suppose. We would have to do that to be able to accurately identify what the profits are coming from Northern Ireland. We need to do that in part, I think, because it is the right thing to do because it is fair to Northern Ireland and the rest of the United Kingdom, but it also happens to be the way that we would need to carry this out in order to comply with the Azores judgment.

Q22 Kate Hoey: Minister, I wonder if you could share with us the secrets of the Treasury. There has been a general feeling that the unity of the fiscal policy across the United Kingdom is a good thing; have you met much resistance if you are going down this line of basically damaging that united fiscal approach?

David Gauke: I think we have to look at this in the context of what is happening with the Calman Commission and the Scotland Bill, which sees a move towards greater localism in the context of income tax. Yes, you are right to say that the traditional position in this country has been the unity of the tax system, but I think there is a willingness to explore greater flexibility where that addresses particular needs. The case in Scotland, for example, is to improve the accountability of the Scottish Parliament and the Scottish Government. The case in Northern Ireland is a slightly different one. It is about strengthening the private sector. So, yes, there are different balances that need to be struck, but the Treasury is more than willing, as I hope I am demonstrating today, to look fairly at proposals that could address some real concerns about different parts of the UK.

Q23 Kate Hoey: Talking about different parts of the UK, what, in your view or the Treasury's view, would be the advantages for the rest of the United Kingdom of this happening in Northern Ireland, if any?

David Gauke: Let me put it this way: if it happens and if it works in the way that the proponents of this policy believe it will, then there could be significant benefits for the rest of the United Kingdom. Not least, it would benefit us all in general terms if the Northern Irish economy were stronger, had a stronger private sector and had higher levels of growth. If we are looking at specifics, this will partly depend upon the final settlement, but for example, the benefit of a reduction in social security costs is something that is likely to benefit the UK taxpayer as a whole.

Q24 Kate Hoey: So you would have no objection then, if you gave the power to the Assembly, of the Assembly going below 12.5%? The argument would be: if we are going to compete with the Republic of Ireland, let's go to 10%. Would the Treasury see themselves laying down certain conditions if they were to devolve the power?

David Gauke: There are various options set out in the paper as to exactly what the model should be. From a Treasury perspective, we are being non-committal on which of those is the right thing. We are keen to hear what the response is from the consultation as to whether, for example, a floor of 12.5% and then flexibility after that is better than starting off at zero and having complete flexibility, or starting at 23% and going 11% either way. We are keen to hear what the response is from the consultation on that.

Q25 Lady Hermon: I wonder if we could move on to what I would call the risks and the downside of this proposal. Again, in the Treasury paper it does refer to the fact—and it is a fact—that "the Northern Ireland executive would bear the fiscal consequences of devolution, including the upside and downside risks if tax receipts were more or less than forecast." I wonder if you could just explore for the Committee what the Treasury sees as the downside and the risks of this proposal of devolving corporation tax to the executive.

David Gauke: What I would say is that an assessment would be made of the cost to the UK exchequer of the Northern Irish rate of corporation tax. That cost would result in a reduction in the block grant.

Q26 Lady Hermon: Is that an immediate reduction, Minister? How does it actually work in practice?

David Gauke: Some of this, to be fair, is to be determined and might well depend upon whether there is a transitional arrangement and so on. I think, though, if we were looking at the steady state arrangement, for every x% of corporation tax, £y million would be reduced from the block grant. That assessment—what is y, for these purposes; what the reduction in the block grant would be—would be something that would be made scientifically with an appropriate methodology, with the best interests of getting the most accurate number possible. However, if following that settlement it turns out that corporation tax revenues were lower than expected, that the Northern Irish economy was less buoyant than was expected, then that is a risk that would be borne by the Northern Ireland Executive.

Q27 Lady Hermon: Are there any circumstances in which the Treasury could comply with the Azores judgment and compensate the Northern Ireland Executive for a loss in corporation tax?

David Gauke: I think the point on the Azores judgment is that it has to be a genuine devolution.

Lady Hermon: Correct.

David Gauke: So that is passed on, and if corporation tax receipts were less than expected—of the devolved element or of its entirety, depending on which model we have used—then that is something that the Northern Ireland Executive will have to deal with, just as if corporation tax receipts turn out to be greater than anticipated, then clearly that is additional money for the Northern Ireland Executive to use as it sees fit and would not be coming back to the Treasury.

Q28 Lady Hermon: Yes. So if the proposal goes ahead, corporation tax is reduced by the Northern Ireland Executive—and it has to be a decision by the Northern Ireland Assembly to do so—but it does not work as well as anticipated, then be it on the heads of the Northern Ireland Executive. That is really the effect of the Azores judgment.

David Gauke: It is a decision for the Northern Ireland Executive to make and there is a shift of responsibility if we go down this, and I am not going to deny that.

Q29 Kate Hoey: Can you visualise, Minister, if it were given to the Northern Ireland Executive, their not actually doing it?

David Gauke: It would be a great pity if we found ourselves in a position where this was devolved, there were additional administrative burdens on businesses that had activities on both sides, and then there was no real desire to make use of it. I think one of the things that we need to take into account if we are going to proceed on this is whether there is a real desire in Northern Ireland to make use of it. The indications I have had though, in particular from my visit on 24 March, is that there is some enthusiasm for this policy amongst the Northern Ireland parties.

Q30 Lady Hermon: Minister, you indicated earlier that you had read the evidence from the previous session, so you will know from your reading of the evidence given by the Secretary of State that, when I asked him if he thought it was a gamble to reduce the rate of corporation tax, the Secretary of State, Owen Paterson, said, "Emphatically, it is not a gamble." Was he wrong to say that to the Committee? Is it a gamble?

David Gauke: The Secretary of State is never wrong in anything he says to this Committee.

Lady Hermon: You are very loyal; that is very loyal.

David Gauke: I think, as Mike has pointed out, corporation tax is a volatile tax, and at times of recession, for example, corporation tax receipts fall quite significantly, and indeed in the years afterwards, because losses get written off. Equally, when the economy is strong they can be very buoyant, but I think everyone is aware of that. There is volatility within corporation tax levels. We would try to make an assessment and try to make a judgment as to what we would expect corporation tax to be, and that will be the reduction from the block grant. Nonetheless, there are consequences. Some might be positive; some might be negative for the Northern Ireland executive if corporation tax does not behave in the way that is predicted.

Q31 Lady Hermon: Yes, and the Azores judgment implies and necessitates the Northern Ireland Executive taking that risk with the block grant.

David Gauke: They must make their judgment as to whether they believe it is in the best interest of Northern Ireland to pursue a policy of a lower corporation tax rate. Presumably, they will do so in the belief that that would encourage greater investment in Northern Ireland, make Northern Ireland more competitive and put it in a position to grow more rapidly than it would otherwise do so.

Q32 Lady Hermon: So is it a gamble, Minister?

David Gauke: No more than any decision has particular consequences. I think "gamble" has a necessarily pejorative tone to it, but there are clearly risks that are involved in any particular decision. The point that the Secretary of State made in his evidence: there are also risks in doing nothing. That is the decision that the Northern Ireland Executive will have to make and question what the biggest risk is; what is, to use your words, the biggest "gamble"? That is something for the Northern Ireland Executive to determine.

Q33 Oliver Colvile: Just slightly pressing you on this issue: I think I understand where your position is on this, but ultimately if the Executive were to make that decision and it were to go wrong, given that you are the Treasury for the whole of the United Kingdom and this is a minor section within it—I'm sure they will hate me for saying that, but there we go—do you see any way in which the Treasury could end up by helping the Northern Ireland Executive through some of the difficulties that might happen? Do you see there are any structural issues underlying all this that could potentially make it very difficult?

David Gauke: One of the challenges—one of the things that could make it very difficult—is if we were in a position whereby we said, "Okay, we are going to devolve this, and if it works well then it is fine, but the moment there are any problems the Treasury steps in and picks up the cost of it," it is at least questionable as to whether that is consistent with the Azores judgment. I think we would have to tread carefully in that area and one would have to look at the circumstances at a particular time.

Q34 Oliver Colvile: I got the very big impression when we went over to Belfast recently that the business community is very keenly interested. However, I think there is a feeling from some members of the Northern Ireland Executive that they need to be a bit more cautious about the approach they take, so there is going to be an interesting debate to see how this works through. What role do you perceive the Office of Budget Responsibility playing in all of this?

David Gauke: Obviously the OBR has a role in determining the overall assessment of what we would expect corporation tax receipts to be, which is the starting point of the methodology in working out what the reduction in the block grant would be. I am not sure to what extent the OBR—Mike, you might be able to help me—will oversee the assessment of what that percentage is going to be, if any. I do not think they have been involved in that process up until now.

Mike Williams: Again, as you said earlier, Minister, that is one of the things that would have to be determined, but plainly the OBR has a central role in determining what the starting point would be.

Q35 Oliver Colvile: That is very helpful. So when you are putting this together, you have obviously looked at a best scenario and a worst scenario. Have you made a judgment about any of that yet or is that what you are going to look at when ultimately you get to the next stage?

David Gauke: We have set out scenarios with different percentages of the overall corporation tax base that we have attributed to Northern Ireland. We have also set out the scenario where there is a transitional arrangement and this is done more gradually. We have not reached a final determination and I think this is one of those things where, if we are trying to work out what the reduction in the block grant will be, it will be constantly refined as we get more information. For the reasons I was saying earlier, we cannot give a precise number as to what the profits are that are attributed and therefore the corporation tax receipts that can be attributed to Northern Ireland. However, that is something that over time I hope we can develop our capability for.

Q36 Oliver Colvile: Like you, I am an English Member of Parliament. Are you seeing that if there is going to be a greater shift away, so that the block grant gets reduced in Northern Ireland, will that be reappraised throughout the rest of the United Kingdom or will you see it as a way of reducing public expenditure as a whole?

David Gauke: I would see that as a reduction in public expenditure, I suppose, but these are all decisions for the Chancellor.

Oliver Colvile: You are his representative here.

David Gauke: But all other things being equal, this would be a shift away from public expenditure towards lower taxes.

Q37 Oliver Colvile: Which ironically could end up producing higher revenue; we have had this big debate during the course of this Committee of an inclination towards Hong Kong, where there was a reduction in the level of the taxation. That actually produced more revenue coming into the Exchequer at the time, so potentially that could happen, which I for one most certainly would very much welcome.

David Gauke: Yes, there is a discussion, particularly in the longer term, about the arguments of the benefits of reducing, in particular, corporation tax, and whether that results in a stronger, more flourishing economy. Obviously, looking at this from a UK perspective, as part of a Treasury that is reducing corporation tax from 28% to 23%, we think that that is a good thing to do for the UK economy as a whole.

Q38 Gavin Williamson: We have touched briefly on this, but how are you going to define who is eligible for the Northern Ireland corporation tax rate, especially if they have operations in Northern Ireland and the UK, or Northern Ireland and the Republic. I am not saying that I would have done this if I were in business, but I could imagine if I had an operation in Ballymena for example and then I had an operation in Blackpool there are ways, which I am sure no business people in Northern Ireland would ever do, of shifting the profitability where the Northern Ireland operation is very profitable but the Blackpool operation is not profitable. How are you going to go about that definition and make sure it is also policed?

David Gauke: It is a good point, and it is one of the challenges that we need to address. It is not entirely a new point, in the sense that any company that operates in two different countries has to attribute its profits appropriately. There are measures that tax enforcement agencies like HMRC take in order to ensure that this is accurate, that revenue is protected and there is a whole transfer pricing regime to do what we can to ensure that profits are not artificially attributed to the place with the lower rate of taxation. There is a need to police that, and there is a role for HMRC to perform in doing that.

As I say, there are mechanisms that are well-established and have long been used because, of course, companies have operated in different countries over centuries and it is already an issue for those companies that operate both in the Republic of Ireland and in Northern Ireland. Yes, you are right though that there is a cost there. We have attributed some costs because we believe there will be some profit shifting that we will not be able to prevent. Nevertheless, we recognise that there is going to be a role for HMRC to prevent that from happening.

Q39 Lady Hermon: So will there be an increase in staff for HMRC in Northern Ireland to police the proposed reduction in corporation tax? Will that lead to more staff being recruited? How will it work administratively? How do you actually do this?

David Gauke: I do not want to necessarily put it in terms of more staff, but you clearly need to improve capability. That might mean more staff directed to this particular area. There is already an HMRC team that deals with transfer pricing, for example, that deals with multinational businesses and ensures that profits are not artificially shifted out of the UK to somewhere else, so this is not an entirely new area for HMRC. But clearly HMRC would need the capability to ensure that those businesses that operate in Northern Ireland and the mainland do not artificially shift their profits.

Q40 Gavin Williamson: Would there be an argument to actually split up HMRC and have a Northern Ireland Revenue and Customs? I am not advocating that at all, but there will be some who do. You can imagine that there would also be, ultimately, arguments on the devolved agenda in Scotland and Wales. Would you envisage it all being very much about one HMRC and just having that different local rule, shall we say?

David Gauke: I suspect there is an argument, but it is probably not a very good one. That would be where I would come out on this. Ultimately, it would be a decision for the Northern Ireland Executive; they would have to decide who they wanted to administer this. I would be very surprised if they did not reach the conclusion that, given that there is an organisation there that would already be administering other taxes in Northern Ireland, such as income tax, national insurance contributions, VAT and so on, the idea of creating a new entity to specifically administer corporation tax in Northern Ireland I suspect would be a policy that would be fairly inefficient, expensive and unnecessary. Again, I think it is probably important to state that these would be decisions that would be made with the Northern Ireland Executive, and I suspect that they would come out with the conclusion that they want to make an agreement with HMRC, requiring HMRC to administer the separate corporation tax rate and regime in Northern Ireland.

Q41 Oliver Colvile: One of the things that I have felt for some while is that we are not very good at understanding unique costs and breaking those down. I just wonder to myself whether there is not an argument to try and do that a bit more, especially here in Northern Ireland, because of what is potentially going to happen. The other question that I suppose I also want to ask you is what the timetable is likely to be in all of this, and where you see all of this going and when you are ultimately going to make a decision? Also, is it the case that you are going to look at inviting the Public Accounts Committee to give you a view on this? We can most certainly look at it from the generic stuff of what we have been doing with the business community and things like that, but it seems to my mind that for you to ultimately make a decision it would be helpful to ask the Public Accounts Committee to see as to what their view is too.

David Gauke: I will take that on board if I may. As far as the timing is concerned, we have not been prescriptive on this; we have not necessarily bottomed out exactly what the timing would be. It partly depends, of course, on what the response to the consultation will be, and we await that with interest. We would need to take a view as to whether this is something that, were we to go forward with it, would require separate legislation—just as the Scotland Bill, for instance, implements the Calman Commission recommendations—or whether this is done through a Finance Bill. We would need to take a view as to what is the appropriate legislative mechanism. Clearly, we want to go forward with a close relationship with the Northern Ireland executive to ensure that their views are fully taken on board. Of course, we would also need the sign off of the European Commission, given the issues relating to the Azores judgment. So it is not really possible at this point to be very specific about what the timetable is.

  But I would also make the point that was made by the Secretary of State: were we to go down this particular route, that could also make an impact on investment decisions some time in advance of any changes in the corporation tax rate because businesses, of course, are looking three, four, five, six, seven years ahead. So the impact of this may well predate any change in legislation.

Q42 Chair: Hopefully this Committee's report will carry some weight as well.

David Gauke: Of course. I should say one of the most significant inputs we are waiting to receive is this Committee's.

Q43 Ian Paisley: The report gives you another opt-out. It says that, if you are going to provide this separate rate of corporation tax to the Northern Ireland jurisdiction, it must be shown that compliance burdens and overall economic benefits are shown to be manageable and justified; it will only be done on that basis, and if the compliance burden is too much it will not be done, so you have an opt-out there. I know we have touched on some of it here vaguely, but what sort of burdens would come to mind for you in that case?

David Gauke: I think the type of issue that we are looking at here is, again, if you have a business that is located both in Northern Ireland and the rest of the UK—and perhaps not operating anywhere else, so not used to the various regimes that apply to multinational businesses—we would need to have an understanding of what the compliance impact would be on those businesses.

As a Government, we are keen to increase simplicity; we want to reduce complexity within the tax system. We need to have an understanding as to: would a separate corporation tax regime in Northern Ireland impose a significant and substantial new burden on those businesses? How do we address those concerns? Do we run into lots of issues with transfer pricing and making sure that profits are not artificially shifted from one part of the UK to another? What are the burdens that will be placed on businesses to ensure that we do not have that leakage from our tax system? Those are the sorts of points that we want to explore because do we suddenly find ourselves with businesses having to deal with a lot more tax bureaucracy that they have not previously had to deal with? Does that damage businesses both in Northern Ireland and elsewhere in the UK? So we need to have an understanding of that and I hope that that too will come through in the consultation process.

Q44 Ian Paisley: There has not been a profit drain between businesses in the UK jurisdiction and the Republic of Ireland jurisdiction, despite the proximity geographically speaking, so hopefully it would not pose a significant problem. But does this opportunity not provide for the Government to obtain another aim that the Chancellor set in his Budget statement—to simplify the tax regime? Could you not see this as a pilot scheme to simplification of overall corporation tax take across the UK anyway?

David Gauke: I think, in all honesty, it is difficult to present this as a simplification of the tax system, because we are potentially applying a different rate to one particular part of the UK. What we need to understand is the extent to which this causes a difficulty. I note your comments about it not particularly causing businesses that operate in Northern Ireland and the Republic of Ireland difficulty, but clearly we need to see the evidence of that. We need to have an understanding of what businesses think about this particular issue. If we do go down this route, I think there could well be lots to be learned across the board as to the impact of it; this is always the tension that exists between localism, centralism and—

Ian Paisley: Competition.

David Gauke: And competition. So I can see the case made that it is an interesting pilot, to use your word, but I would not present this, by any means, as a tax simplification.

Chair: I think we are going to vote at 4 o'clock, so perhaps if I could ask for slight brevity. I did not mean that by way of introduction, but Oliver.

Q45 Oliver Colvile: I am the one who has become the butt of the jokes in this place. Anyway, if this goes through and it is successful then obviously there is going to be an increase of business activity within Northern Ireland as well. That potentially could deliver increases in VAT, income tax, national insurance and all those kinds of things. Have you considered ways, and do you think you are likely to come under pressure from the Northern Ireland Executive, to share some of that increase in tax take with the Northern Ireland Executive as well?

David Gauke: Within the consultation paper we do include some numbers there looking at what I think we describe as the indirect tax effects, but exactly as you describe it, Mr Colvile: the impact on VAT, income tax, etc. We have not reached a conclusion as to whether that should be taken into account in the assessment of the block grant for a couple of reasons. One, there is an inherent uncertainty as to what those numbers are. It is even more difficult to predict what those numbers might be. Secondly, there is an issue that comes back to the question of risk, because if we start to take into account those numbers, if they turn out to be inaccurate there is a question of who bears the risk. No decisions have been reached on that. I imagine that we will come under pressure to include those indirect tax effects, but we have not reached a conclusion on that point. They are included in the paper, though, as an illustration of what we think they might be.

Q46 Kate Hoey: I just wanted to check about whether the Treasury is distancing itself now from the Varney Report, which talked about quite significant displacement of receipts and capital from the rest of the UK?

David Gauke: We have, again, within the paper included some numbers of where we see displacement from one part of the UK to Northern Ireland. Those numbers are included. To some extent, this is new analysis. Obviously, the Varney Report was a few years ago and under a previous Administration, but we have come up with fresh analysis. But the point about displacement is a perfectly fair one and is incorporated within the numbers we have included in the report.

Q47 Lady Hermon: Could I just come back to a point that was raised by one of my colleagues here just a moment ago? Could I just find out whether in fact everything has to be agreed before anything is agreed, if you know what I mean? In other words, we have to work out, if there were a VAT increase, whether in fact Northern Ireland would benefit from that and other additional taxes. Minister, if I understood you correctly, and I think I did, you said that in fact all of that would have to be calculated and decisions would have to be made on that. Would all of those decisions have to be made before we are compliant with the Azores judgment? Is it going to be a gradual thing?

David Gauke: No, I think we are looking at the indirect tax effects, for example, there is a question as to whether that could be included within the Azores judgment. We do not have a final decision from the European Commission; we would need to go to the European Commission formally to obtain their consent to that being included. That is my understanding as to how we would have to do it. I think we can make considerable progress on this without necessarily having everything bottomed down before we go to the Commission. Indeed, we have informally met with the Commission to identify any showstoppers, and we do not think there are any showstoppers at this point. However, as the details emerge and as various decisions will be made, as far as the European Commission is concerned I suspect it will be a somewhat iterative process. We will go to the Commission with an outline of what we would have in mind and then go back to them as further details are sketched out.

Q48 Lady Hermon: Sorry, just explain please, if you would, to the Committee, the sequence of events. We have an Assembly election on 5 May; we have a new Assembly; we will have a new Executive. Then what happens?

David Gauke: Obviously, once we have completed the consultation on 24 June it will be a question of the Government as a whole looking at the various responses to the consultation, looking at the report of this Committee and other responses, and taking a view as to how we proceed, assuming we want to proceed. That is something that we would work very closely on with the Northern Ireland Executive—

Lady Hermon: The new Executive.

David Gauke: —to fill in the details, to reach conclusions on some of the decisions that would remain open, and we would work as openly and co-operatively as we could in order to develop that.

Q49 Lady Hermon: And does this work in tandem? Obviously, with the Northern Ireland Executive, we anticipate there will be a new Executive with new Ministers in place from various parties, who all have to agree to this and have it explained to them in great detail. Does this consultation work in tandem with negotiations with the European Commission?

David Gauke: As I say, we have informally met with the European Commission.

Q50 Lady Hermon: Once? Twice? How often?

David Gauke: Just the one meeting.

Lady Hermon: Just once to discuss this?

David Gauke: This is at an informal level. As I say, this is still very much developing as a policy. We are at the consultation stage. As it becomes more detailed then there will be further discussions with the European Commission, and then ultimately we would take this to the Commission as a pretty well-developed policy, assuming we go down this route, for the Commission to confirm that we are compliant with the Azores judgment.

Q51 Chair: I want to bring Oliver in on the European issue in a moment, but I must admit I am a little bit confused about how we go about this, because we presumably would have to pass primary legislation in this place and then we have to run off to Brussels and say, "Is this okay? Is that okay?" It is a little bit confusing about how it would work. Maybe it is to you as well, I don't know, but it certainly is to me.

Lady Hermon: It is to us—it is to the Committee, if you could clarify.

David Gauke: As I say, I think it is an iterative process and, in some respects, not that unusual because there are all sorts of areas where compliance with EU law is an issue and restricts the policy options that are available to Governments on a pretty regular basis.

Q52 Chair: It is indeed, but we have recently passed an Act saying that this place is supreme. I have been to discuss it with the Commission myself and the problem in discussing anything with Europe is you do not get a yes or a no—as you are well aware. I am not quite sure how we would pass legislation here and have Europe challenging it. It is very confusing.

David Gauke: The intention would be to produce legislation that was consistent with the Azores judgment. Clearly, we would take our view as to whether any proposed legislation was consistent with the Azores judgment. Clearly, it is advantageous for that view to be as well informed as possible. Consequently, I would anticipate that there would be ongoing informal and maybe formal conversations with the Commission to ensure that we were not heading down a track that would result in infraction proceedings one, two, three years down the line because that is in nobody's interest.

Q53 Chair: The Basque ruling as well, presumably.

David Gauke: Yes.

Q54 Oliver Colvile: Have you begun to have any formal discussions with the European Commission?

David Gauke: Informal discussions, yes.

Oliver Colvile: Yes.

David Gauke: Not formally, but yes, there has been an informal meeting at official levels.

Q55 Oliver Colvile: And who ultimately will be responsible for it? Will it be the Treasury? Will it be the Northern Ireland Office? Who is going to take ownership of this?

David Gauke: The experience we have had so far is a very co-operative one of both the Northern Ireland Office and the Treasury, and I am not sure whether the Northern Ireland Executive is involved as well. Mike, you want to say a word or two about that, but that was a question of all the various parts of Government, both at a UK and Northern Ireland level, working together to get an indication as to whether there were any particular problems at this stage, when we are starting our consultation process. That was a reasonably positive and encouraging meeting, as I understand it, although Mr Robertson's description of not necessarily getting a yes or no is not too far off.

Q56 Oliver Colvile: Do you think they have noticed that we have passed this Act that gives us supremacy over this?

David Gauke: I was not present for the meeting so I cannot report on that.

Q57 Lady Hermon: I did want to come back and ask the Minister one further question, not necessarily about that, because we have looked at the differences between the Republic of Ireland's corporation tax. I would like a clarification following on from our discussion about the Azores judgment and its implications? I am quoting from a very interesting paper that I am sure you have already read, and this is by PricewaterhouseCoopers, published in January of this year, called Corporation Tax - Game Changer or Game Over, which is a great title I think.

The issue that I wanted clarification on from you, Minister, is right at the very beginning and it directs the question about what we are devolving to the Northern  Executive, and I am quoting directly here: "If Westminster invokes the Azores judgment"—which is precisely what you would like to do or have to do with the Commission in order to clear this—"If Westminster invokes the Azores judgment it could facilitate the executive"—meaning the Northern Ireland Executive, obviously—"to strike a regional rate of corporation tax. However, invoking the Azores judgment may also confer on the sub-region"—I have never heard Northern Ireland called a sub-region before, but that is Northern Ireland—"the ability to vary other taxes and not merely corporation tax." Is that the case? If Treasury, the Northern Ireland Office and the NIE all satisfy the Commission and get a yes from the Commission that corporation tax should be devolved, does that actually extend to other taxes that could be collected by the Northern Ireland Executive? This seems to be the issue raised in this very interesting paper.

David Gauke: No, I would not agree. That is not the view that we have. It is perfectly possible to devolve corporation tax in isolation. That does not mean that, for example, income tax becomes devolved as well; it is perfectly possible we just do corporation tax and be consistent with the Azores judgment.

Q58 Lady Hermon: And do you feel confident that is consistent with the Azores judgment?

David Gauke: Yes.

Q59 Chair: Could I just ask you then, just moving slightly wider with regards to enterprise zones? We have tended to focus on corporation tax this afternoon, which is fine. It may not be entirely your responsibility, but are there other ideas that will be brought forward by the Government in terms of enterprise in general?

David Gauke: As you will be aware, obviously the Budget contained a whole host of measures that are designed to encourage enterprise that apply across the UK, and we already have in place, for example, the national insurance contributions holiday for start-up businesses in Northern Ireland and many other parts of the United Kingdom. You will also be aware that the budget contained proposals for 21 enterprise zones within England. This is largely a devolved matter and consequently it was not for us to make announcements about enterprise zones in Northern Ireland, although it is worth pointing out that the key policies as part of the enterprise zone announcements were focusing on business rates and planning, both of which are devolved matters in Northern Ireland. So if Northern Ireland wants to move towards more enterprise zones along the lines of the 21 that we have announced in the Budget, that is a matter for the Northern Ireland Executive rather than the UK Government.

Q60 Lady Hermon: Before we get to the cut-off at 4 o'clock, I am sure someone will have advised the Minister how many companies in Northern Ireland pay corporation tax.

Chair: Yes, yes—good.

David Gauke: Yes.

Chair: There we go.

Lady Hermon: Lovely. Thank you so much. That is so nice of you. You have had inspiration.

David Gauke: Yes, I mentioned the 60,000, which I plucked from the air. We think it is around 66,000.

Lady Hermon: 66,000—

David Gauke: 66,000.

Lady Hermon: —who pay corporation tax in Northern Ireland.

David Gauke: I think it is 66,000 that are in Northern Ireland, of which between 50 per cent and 63 per cent—it has been a different number over recent years—pay corporation tax. But I will write to confirm that, if I may.[2]

Chair: That will be super, thank you.

Lady Hermon: Yes, it is.

Q61 Gavin Williamson: I have to confess, Minister, I have a pathological hatred of Her Majesty's Revenue and Customs, and I am probably not a lone voice in that. I am sure there are many decent and good worthwhile people that work in that organisation.

Lady Hermon: Sorry, could I just interrupt my lovely colleague just to put it on the record that in terms of dealing with organised crime in Northern Ireland, HMRC is very effective indeed. I pay tribute to the HMRC in Northern Ireland.

Gavin Williamson: And that is a real credit to them, but I always have a great concern about any moves that would ultimately create a bigger organisation. Unfortunately variances such as this would inevitably probably create more work and therefore a greater burden on everyone else. Oliver mentioned at the start about the urge to go lower in a UK corporation tax, and I just wondered if I could take this opportunity to bend your ear to maybe bend the Chancellor's ear that really what we want is a 12.5% UK rate of corporation tax, and I am sure it would pay great dividends—

Chair: I am sure it would.

Gavin Williamson: —every step of the way, especially for the people of South Staffordshire, as well as the people of Northern Ireland.

Oliver Colvile: And Plymouth as well.

Gavin Williamson: So if you could just really push that agenda forward.

David Gauke: I am tempted to respond by echoing the Speaker saying, "I am not sure that was a question, but you have put your point on the record."

Gavin Williamson: That is very true.

Q62 Oliver Colvile: Just one final little point from me: do you perceive, if this were to go ahead, that there would be an increase in bureaucracy? Would the Northern Ireland Executive suddenly find itself having to set up a separate Department within Northern Ireland in order to monitor all of this to make sure that—?

Gavin Williamson: And would that be part of the bill of the extra—?

David Gauke: Again I stress that this is a decision for the Northern Ireland Executive. The likelihood is that HMRC would perform the administration task and, yes, there presumably would be a burden on businesses that operate in both jurisdictions. I think one of the things that it would be very good to get out of the consultation process is a sense of the extent of that burden: how big a problem is it? That is something that we need to learn more about and that is why we should engage with business groups, for example, to have an understanding of it. I think that is the likely answer, but as I say, it is likely to be HMRC that would perform the work.

Q63 Kate Hoey: Just quickly, if the Treasury seem to be perhaps quite keen on this devolving power to the Assembly, would they also give the Assembly power to reduce the air passenger duty, which has huge implications for not just small businesses but ordinary travellers from Northern Ireland, who really have no other way but flying and are continually being penalised?

David Gauke: I am conscious that this is a particular issue for Northern Ireland, and the concern about the continental flight to the US, and the competition coming from the Republic of Ireland. We are currently consulting on APD; we have decided not to go down the route of a per plane duty because of various legal difficulties.

Q64 Chair: Is that yet or ever?

David Gauke: For the foreseeable. It is not a tax on which I lead, but as I understand it whilst the Chicago Convention says what it says, it is practically not possible to go ahead with a per plane duty. However, we are consulting more broadly, including on the point about devolving air passenger duty. Again, we look forward to receiving responses to that consultation, which I believe closes on 17 June.

Q65 Gavin Williamson: We are talking about the extra cost on the HMRC. Let's say hypothetically that was £10 million, would that be billed to the Executive in terms of obviously a cost of the administration of this?

David Gauke: Apologies, I should have picked that up in the earlier answer. Yes, it does. So the additional cost would need to be picked up by HMRC,[3] but that is not to say that the existing costs of administering corporation tax and other taxes at HMRC within Northern Ireland will be passed on. It will be the additional cost. Again, that is something that we believe will be necessary to be consistent with the Azores judgment.

Chair: It has been a very useful session. Minister and Mr Williams, thank you very much for joining us.




1   Note from witness: The paper looked at companies registered for tax purposes with a UK postcode. Back

2   In any given year there are around 66,000 registered companies resident in Northern Ireland. Of the companies active in recent years between 50% and 55% paid corporation tax, although this percentage varies from year to year. Back

3   Note from witness: Additional costs would be picked up by the Northern Ireland Executive. Back


 
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