Mr. Brian Keegan:

One would be foolish to suggest otherwise if for no other reason than when a dispute arises, it can drag on and on. The down side of it is that, unfortunately, it is the best we have at present. One has to work with what one has. Because transfer pricing issues tend to be cross-border by definition, one cannot make up one's own transfer pricing rules and go over to the neighbouring revenue authority and state, "By the way, we are tackling it this way this year", because they will merely laugh one out of court.

If we make a mistake, it would be not to engage in ways of improving the transfer pricing regime. That is an ongoing process and, as far as I can see, there is reasonable involvement by the Irish authorities.

I have no fundamental issues with what Mr. McCaughey is saying but, unfortunately, sometimes one has to play with the hand one is dealt, irrespective of how satisfactory or unsatisfactory that might be.