I`ll be very fast for the rest of the time. There is a nuance in our existing law. Will this agreement, which will be signed and ratified again this year with the Netherlands and Switzerland and with others, including Luxembourg, consider the permanent establishment of existing companies or will it apply only to new branches that will change after that date? The Federal Council`s decision is implemented within the framework of bilateral double taxation agreements. Greater information exchange will only have a practical effect if the renegotiated agreements come into force. In addition, adjustments must be made to the agreement with the EU on the taxation of savings. I am pleased to be here to present two draft government decisions to the Committee which, in Ireland, approves a new alternative double taxation agreement with the Netherlands and a new protocol to the current double taxation convention with Switzerland. The new double taxation agreement with the Netherlands was signed on 13 June 2019 by the Minister of State, Mr O`Donovan, Vice-President, on behalf of Ireland and Foreign Minister, Mr Blok, on behalf of the Netherlands, as part of the State Visit of their Majesties, King and Queen of the Netherlands, to Ireland. The protocol to the Double Taxation Convention with Switzerland was also signed on 13 June 2019 by the Minister of State, Vice-President D`Arcy, and the Swiss Ambassador to Ireland. Most contracts normally follow the OECD standard contract. Double taxation is generally avoided by the application of the “progression exemption” method, i.e. all income is taken into account in determining the applicable tax rate, but no tax is actually levied on exempt income. The inescapable foreign taxes on capital income (interest, dividends) are generally credited on and up to the real Swiss tax on these incomes. Unused credits cannot be presented.
Last year, we also suggested that the double taxation convention with Germany would be updated bilaterally in a timely manner. Discussions with Germany on this issue are at an advanced stage. With regard to partner countries that have not yet signed the BEPS multilateral convention, Ireland has written to them to discuss options for implementing the BEPS PROGRAMME recommendations. We are committed to ensuring that all of our double taxation agreements meet the minimum standards agreed as part of the BEPS process. Some of the countries that have double taxation agreements with Switzerland are: what other agreements or protocols are along the way? I got a call from a local shopkeeper who employs a lot of people in a particular village. The Income Commissioners were like a ton of bricks on the store because it facilitated the sale of mass cards for the local church. The store did not benefit at all, but the Revenue Commissioners argued that this could have increased the flow in the store, since someone could enter for a mass card, but at the same time get a loaf of bread. In the agreements I am talking about, it is not a question of paying 5 euros to show compassion and respect for someone who has died, but hundreds of millions of euros in confusing systems that allow the transfer of assets abroad, with credits generated on the basis of these assets in order to allow a total neutralization of profits here. This means that some of the largest companies on this island do not pay their fair share of taxes if they pay taxes. Will these practices continue to be allowed under this agreement and the agreement to be signed in November of this year? Ireland first signed a double taxation agreement (DBA) with the Kingdom of the Netherlands on 11 February 1969.