Mr. Eamonn O'Dea:

The figures would speak volumes if we had somehow created the intangibles concerned, if we had funded the research and development of those intangibles, if the ownership, the licensing, the registration, etc., were here, and if they were our assets that we were entitled to take the return on and charge. However, in this country, as in other countries, if the property is created outside the State, has no connection with the State and is owned by companies that simply are not Irish resident - they do not have a connection - they have to be remunerated.

Profitability may vary. I am not familiar with the particular figures Deputy Pearse Doherty quotes but the intangibles concerned have to be remunerated. They are not Irish assets and the remuneration of those assets is not Irish income on which we are losing out tax in some way or other. They are a cost of the business that is being done here - the manufacturing, the production, the services or whatever - and what we do at the outset is try to establish, if it is a branch operation here, a proper attribution to the activity that is here proportionate to the activities here, taking account of the functions, the assets used and the personnel involved, here and elsewhere.

We take a facts and circumstance approach. There is no standard approach. There is no rule of thumb. We are not somehow letting a chargeable income that should be chargeable here drift off to some other jurisdiction.

The fact is there are in many cased extremely, uniquely valuable assets held outside the State and they have to be remunerated. They were not created here and if the company or branch that is operating here wishes to license in those, it has to pay for them.