Professor Frank Barry:

All of the questions so far have been really interesting. The perspective of the IDA, and I believe it is right on this, is that we stand to benefit from any changes at the global level. I am a little sceptical about whether radical changes will happen but the IDA says we stand to benefit because we have the substantive activities here. Deputy Pearse Doherty was correct when he said that the 1999 changes were not a direct response to check-the-box. I was simply making the point that they did not respond to check-the-box in a way that would facilitate further tax avoidance. The fact that we insist that any companies using Ireland have substantive activities here must stand the test of time and will stand to us whenever any changes are introduced at the global level that apply to all countries. The country that will lose out there is the Netherlands, besides the countries that used to be called tax havens. Most US foreign investment that comes to Ireland comes through the Netherlands, through Dutch holding companies, for tax reasons. The Netherlands does not require substantive activities. We are protected to a large extent in that regard.