Mr. Conor O'Brien:

The Deputy is absolutely right and that is the reason there is an industry of transfer pricing experts. We have a substantial team of transfer pricing experts in our office, as do many of the companies and the revenue authorities all over the world. The Deputy is right that in this case, one is selling to oneself and consequently, the question is how do we know if the price is at arm's length. What they do is to find comparable situations, insofar as they can, where a third party is involved. For example, many sophisticated manufacturing companies and many sophisticated brands get their manufacturing done by third parties, that is, by contract manufacturers as they call them. Transfer pricing experts try to ascertain what profit margin is retained by a contract manufacturer and what profit accrues to the brand owner. Thereafter, one has a debate with the tax authorities as to what is the appropriate pricing. That is an entire industry.