Brian Hayes (Dublin South West, Fine Gael) | Oireachtas source

In all cases we attempt to obtain a double taxation agreement. We have 69 such treaties in place, as I said, and have given a commitment to the OECD to ramp that number up significantly. If securing a DTA is not possible, whether because of concerns on the part of the other country or whatever, a tax information exchange agreement is the next option.

We should bear in mind that these are bilateral arrangements which require two parties to come to the table. It is quite often the case, for instance, that negotiations will commence but not conclude, which is a real problem in the case of our engagement with certain emerging economies. I have made that point to the finance committee in the past. There are countries in South America, in particular, with which we would like to secure an agreement but, for all types of reasons, we have not yet managed to bring discussions to a conclusion. It is not a case of our seeking to secure the most minimal agreement. On the contrary, we always seek to achieve the most extensive agreement possible, but whether that is possible is effectively a matter for the third country to decide.