Mr. Brian Keegan:

The system is known as the mandatory disclosure regime. If a series of transactions meets a set of criteria and they are entered into, the accountant must notify Revenue that this is happening. If, however, those transactions are being facilitated by the legal profession, all the legal professional has to do is recommend to client that the client advise Revenue. It is a different emphasis and burden of requirement. We are concerned. For this important area there should be a level playing field if possible. We understand the legal professional privilege is a concept which predates the tax system and is external to it, but there must be some mechanism whereby an even-handed approach can be fully taken.