Temu tax residency
Deputy Gibney asked whether the Irish management of PDD Holdings and its Temu subsidiary create tax-residency implications for the company. The Minister refused to discuss any individual taxpayer’s affairs, said tax rules are clear, and directed her to Revenue and Finance for general guidance.
According to the annual report of PDD Holdings - the company that owns Temu, a discount e-commerce platform that I am sure the Minister is familiar with - its jurisdiction of incorporation is the Cayman Islands. On the same form, it is stated that the company's principal executive office is here in Ireland. A company incorporated in a foreign jurisdiction and managed from Ireland is tax resident here. The subsidiary which operates Temu, namely Whaleco Technology Limited, is also Irish registered. We need clarity about whether tax residency and incorporation arrangements like this impact the taxation of financial flows between large parent companies and subsidiaries. I am concerned that this structure of tax residence between two jurisdictions allows tax avoidance by multinational corporations in the same way that the so-called double Irish, which was discontinued in 2015, did. Is this being looked into? Are we applying a withholding tax on payments from Ireland to PDD Holdings, given that the company is incorporated in the Cayman Islands?
Comment on this
I do not have the individual taxpayer information, nor should I comment on any company's individual tax information in the Houses of Oireachtas. We have very clear legislation that sets out the tax arrangements for corporations, businesses and individuals.
Comment on this
What about the broader picture?
Comment on this
If the Deputy has a particular question, both the Revenue Commissioners and the tax division of the Department of Finance can clarify any interpretation of general policy. Individual taxpayer information is a matter of either personal or corporate confidentiality. It is important that we uphold that principle.