Mr. Eamonn O'Dea:

I thank the Deputy for that question because it is very useful to clarify emphatically that it is not a question of semantics. There is no question of only saying we do not do a special deal or we do not do a special rate deal. We simply do not do special arrangements as such. As for the suggestion that if we do not do special rate deals and do not have some kind of special rate for large companies, we might have a special formula that reduces the base, thereby effectively giving them a low rate, the answer is "No, we do not." We deal with the facts and circumstances of the companies in question. They will set out for us what their operations in the country comprise and how they relate to other parts of the company if it is a branch located here. Consequently, it is on that basis, looking at the specifics, that it could be cost plus, cost plus and a percentage of receipts, or a profit split. There are various methods, but it depends on the facts and circumstances involved. We do not have a formula that we will apply on a rule of thumb basis to these companies in general. Moreover, it is standard practice internationally to be obliged to deal with the attribution of profit to the branch. That is an important point, coming back to the earlier point that I only want to speak about in general terms, that one could attribute a low percentage rate to Ireland. One can only do so if one takes non-Irish profits, that is, profits not attributable to the operations of an Irish branch, into the reckoning or equally, were one to take in-----