Mr. Pascal Saint-Amans:

That is a difficult question because it would require some anticipation of being part of the action plan and the fact that it is properly and fully implemented. Let us assume that is the case because we have worked very hard to make this happen. That would mean we would reconcile the location of the real activity and the location of the profits. Companies would no longer be allowed to play on the rules to erode the basis in countries where they operate and locate the profits in jurisdictions where they do not operate. Of course it is hard to do such abstract reasoning. Deputy McGrath knows better than I that there is some special interaction between Ireland and the United States and the way the US tax system is designed. The action plan is not fit to change US domestic law. That is a question of tax sovereignty in the US. I am pretty sure Deputy McGrath knows as much as I do about the current political debate in the US which is happening on Capitol Hill, both in the House of Representatives and in the Senate, to change US tax law.

The next action plan will have an impact but from an Irish perspective I guess it also depends on reform of tax policy in the United States.

To take some risk in responding to Deputy McGrath's very interesting question, I would say - and I am not saying this because I am addressing Irish parliamentarians - that the implementation of the action plan should not reduce Ireland's competitiveness but may result in more real business being located in Ireland and not real business moving away from Ireland. I do not see any negative impact but rather a positive impact because closing these avenues which facilitate double non-taxation will make it more interesting or important to locate the real profit in jurisdictions that are competitive with our tax system, which is the case-----