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?

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What about the broader picture?

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