Ms Josephine Feehily:

The Deputy answered the question himself by asking whether I subscribe to the view he articulated. The legislation provides what it provides; our job is to administer it. The question of the allocation of profits has been settled in the context of OECD model treaties, which reflect very old rules going back to colonial days when they were designed for a particular purpose. We work within those global rules and within the domestic legislation. The question of whether it would be good, bad or indifferent to change those rules is not a matter for me.