Mr. Brian Keegan:

Revenue authorities are fairly circumscribed in what they do. They have almost absolute authority within their own jurisdiction. Everything else has to be done by way of negotiation under international treaties.

Incidentally, I do not accept that the transfer pricing issue is something that is confined to multinationals. One could have a firm in Newry and a firm in Drogheda engaging in cross-Border trade which could conceivably benefit from transfer pricing abuses. I also do not think that we are quite as bad at it as is portrayed.

The last point I would make is that one of the big issues with transfer pricing - Mr. McCaughey referred to it early in his presentation - is the difficulty of assessing what the correct position should be. To be fair, we have seen a lot of unprecedented stuff in the past ten to 15 years simply by virtue of the fact that the reliance by multinationals on their intellectual property has grown and the ability of a company to fairly and honestly state that X amount of the value of that product relates to the research it has done on it and Y amount relates to the materials and physical manufacture are challenges, not only for the Revenue authorities but also for the companies themselves, and we are working through a process.