Mr. Gary Tobin:

It is always possible to change our tax residency rules. It would, therefore, be possible to do what the Deputy suggests and this could have an impact on certain tax structures. The sad reality is that a variety of what are termed "two-tier" structures are in place. These are not in any way reliant on Ireland. If we unilaterally change our rules and nobody else changes theirs, the impact would, arguably, be very limited. That is why the work taking place at international level is so important. One of the things I did before this meeting was to read Mr. Pascal Saint-Amans testimony to it. Mr. Saint-Amans referred to an interesting matter and indicated, in his opinion and in answer to Deputy Boyd Barrett:

[W]e believe we first need collectively to address the deficiencies of some of the international tax rules ... it is not something to be addressed unilaterally by one country as we need an international consensus to change the rules. The current rules in Ireland are compatible with the international consensus. What is wrong is not the current rules in Ireland, it is the international consensus. We agree that needs to change. Afterwards, as I indicated, countries can take the unilateral decisions they have to take, and it is within their own sovereignty to do so

He seemed to be suggesting that - in his view - the international rules should change first and then the national rules should do so. Ultimately, it is a policy choice.