Mr. Eamonn O'Dea:

It appears that some confusion may have arisen. To some extent it is speculation. We would not wish to speak about a particular case other than what was mentioned in public hearings and what may have been involved. An issue did arise going back to the 1980s. At that time export sales relief was still in place. This was the initial approach to a competitive corporation tax regime - and to which Professor Barry referred yesterday - which was introduced in the 1950s. However, that changed in 1980 when we moved to a 10% rate for manufacturing relief. There was a period from 1980 to 1990 when companies that had already been investing and had substantial operations in Ireland focused on exporting and availing of this export sales relief. Their profits continued to enjoy the benefits of this export sales relief for a further ten years from 1980 to 1990. Every walk of life has its own jargon or technicalities but certainly in tax there is often reference to grandfathering where an arrangement is carried over for a specified time. In this case the carryover arrangement was set out in law and it was part of our statute that while we were bringing in an effective 10% rate, by virtue of manufacturing relief, at the request of the European Union, for a transitional period, for a ten-year period, export sales relief would continue to be available for companies already entitled to it. That may have been what the references to grandfathering referred to.