Professor Frank Barry:

Clearly not. However, that is one way of closing it. As long as there are differences between the tax laws in jurisdictions, high-paid lawyers will find ways to exploit them. The only real way of closing down this opportunity is to adopt American tax law, which none of us support. Let us say we closed this down significantly. Multinationals, which are located in 180 countries worldwide, will continue to seek to identify differences between US tax law, which is the one with which we are most concerned, and other countries' tax laws which they can exploit. If Ireland no longer offers them the opportunity to do so they will seek to identify those countries which offer significant opportunities.

I referred earlier to the introduction in Britain of the patent box and to the Netherlands keeping an eye on what we do. Singapore and Ireland are in strong competition. There will be other countries that will not have totally closed down the opportunity for multinationals to operate between the cracks, which is what they do. We could do it but it would be hugely detrimental to us and the companies would go elsewhere and exploit the cracks between those other jurisdictions' tax code and that of the US. Why would we do that? Why would we shoot ourselves in the foot? At national level, we claim to support what the OECD is trying to do - that is, addressing this at a multinational level, which, as I stated earlier, we stand to benefit from. Obviously, in trying to do the right thing, we have to take into account the interests of the country.