I want to raise the matter of the Paradise Papers and the information which has emerged in regard to Apple's tax arrangements, the facilitation of these arrangements by successive Irish Governments and the considerably negative impact this is having on Ireland's reputation. The central theme running through the Paradise Papers is the relentless quest of the wealthy and powerful, the great and the good, to find ways of avoiding paying tax. We saw this most starkly in the operation of the double Irish and its use by Apple and the subsequent ruling by the European Commission that this favourable treatment constituted state aid. In that regard, it certainly seemed that the facilitation of tax avoidance was an intentional strategy adopted by the Government and its agencies in 1991 and updated in 2007.

It is very hard to understand why the Government, in September of last year, with the full benefit of hindsight, stood over the manner in which the sweetheart deals were done and vouched for their full compliance with the law. The public cannot understand why the Government is now spending considerable additional millions of euro on appealing the European Commission ruling.

The position of the then Minister for Finance, Deputy Michael Noonan, was very hard to understand. In 2013, he signalled that he intended to close down the double Irish on which the tax avoidance arrangement is based. The impact of this was considerable for Apple's tax liability. We know there was much engagement between Apple and the Department of Finance around this time. We also know, thanks to the Paradise Papers, that Apple went on a jurisdiction shopping spree in search of another tax-dodging deal, and that following the closing of the double Irish, Apple restructured its companies. It registered two of its Cork companies in Jersey and took up tax residency in Ireland for its remaining Cork company, Apple Operations Europe. This, combined with the changes made to the capital allowance regime in 2014, allowed Apple to sell its intellectual property back to the Irish-registered company and avail of the massive tax breaks which this measure facilitated.

Was our capital allowance regime changed to allow Apple to keep its formerly stateless profits entirely untaxed? In other words, was it done to compensate Apple for the loss of the double Irish? Had Apple, or its representatives, requested a change to the capital allowances regime? How much has Apple benefited by this change and how much has the State lost?

The answer to the Deputy's question is "No", or not to my knowledge. She might wish to put the question to the Minister for Finance who might have more information on those matters than I do. I do not have detailed knowledge of any company's tax affairs or, indeed, any individual's tax affairs.

Tax avoidance is an international problem and international problems require international solutions. As we found when it comes to dealing with tax avoidance by large companies, when one country acts, the company will just move to another jurisdiction.

That is why we need an international solution to this problem-----

It is inertia.

-----in order to bring about a situation where companies pay their fair share of tax. In that regard, Ireland is an international leader. The Organisation for Economic Co-operation and Development, OECD, which is based in Paris is the international organisation which deals with taxation issues and ensuring companies are not able to exploit differences in tax law from one jurisdiction to the next. It has designated Ireland as one of only 22 countries, of nearly 200 in the world, which are entirely compliant when it comes to tax transparency. We have also signed up to information sharing. We are going to share information from one country to the next on how much each company is paying in tax in different jurisdictions. That will prove very useful as for the first time we will know how much a big company has paid in tax in Ireland, how much it has paid in France and how much it has paid somewhere else. We did not know that information up until now. The double Irish is gone. Stateless companies are also gone. The Finance Bill 2017 will change the way in which we tax intellectual property. However, we do not accept at all that Ireland was involved in any special arrangement with, or in providing state aid for, Apple. That is why we are fighting the case.

That is the core of the problem.

It is simply not the case that Ireland was involved in providing state aid.

On the Paradise Papers, there are 13 million of them and I doubt that anyone has read them at this stage. I am sure this is still an evolving story. The Revenue Commissioners will examine the papers. The Minister for Finance has already spoken to the chairperson of the Revenue Commissioners about this matter and if further action is required to be taken against any person or company, it will be taken. It is important to point out that the Revenue Commissioners have been very active and effective in this area. In the past couple of years alone they have collected €1 billion in targeting offshore operations by companies.

It is a cop-out to say the issue of tax avoidance needs international solutions alone. Yes, it does need them, but it also needs us in Ireland to close the loopholes which Governments have created, including the double Irish in 1991 and the changes to the capital allowance arrangements which the Taoiseach's Government introduced just last year. This greed fuelled quest to pay no tax is, of course, not victimless, of which the Taoiseach must be aware. The victims are small and medium enterprises - indigenous industries which are tax compliant and which do not have access to the tax avoidance advice available to multinational companies. Compliant taxpayers are also victims. They are denied adequate funding for the provision of public services owing to the reduced revenue base.

The Taoiseach says the intellectual property arrangement has been closed. It has been closed but not before Apple was allowed a ten-year break as a result of the changes made last year. The Comptroller and Auditor General recently noted that the cost of capital allowances had doubled between 2014 and 2015. How much of this was due to Apple's restructuring? How can we allow one company to completely dominate and distort the national accounts? The Taoiseach is answerable for this. He is the leader of the Government and must answer for what his Government has done.

I do not accept that it is a cop-out. It is the case that, if one listens to what the Deputy is saying, she agrees with me. This is an international problem which requires an international solution. If a loophole is closed in one jurisdiction, companies simply move to the next. I do not accept that saying this is a cop-out. It is a statement of fact.

The Government created a new one.

That is why we need an international solution to this international problem. I agree that we must close loopholes domestically. I gave the Deputy two examples of loopholes which we closed in recent years, one being the double Irish-----

It is still operational.

-----and the other being a mechanism which allowed stateless corporations to avoid paying tax, but it is a constant game of cat and mouse. There are very smart tax lawyers who go through legislation looking for loopholes to exploit. It is never going to be the case that there will be no loopholes and we must keep on closing them. The Deputy knows full well that it is not possible to change the law retrospectively. That applies to citizens, as well as to companies. We could not pass a law here today to change the income tax rates four years ago and expect people to pay up. Laws have to be prospective, not retrospective.

Why did Deputy Michael Noonan do it?