Ms Cora O'Brien:

On the issue of the definition of residency, if a company is managed and controlled in Ireland then it is subject to Irish tax on its worldwide income. We have a worldwide tax system. If it is not managed and controlled in Ireland then it is subject to Irish tax on the profits that are attributable to Ireland. Those are the rules in terms of Irish residency.

The question of whether we change the residency rules is a matter which is open to discussion in the Department of Finance's consultation paper that has been published. There has been comment in the media about the possibility. It sounds like it may be possible to extend the definition of residency to something similar to what the UK has done, although there are exclusions to the UK incorporation test as well.

The residency issue is quite clear. If one is managed and controlled here then one is taxed on everything in Ireland. If one is not managed and controlled here then we have no entitlement to tax profits that are not attributable to activities that are carried on in Ireland. That is regardless of the rules for VAT, PAYE and PRSI. It is not any sort of statement of the rights and wrongs; it is just a statement on what the law is at the minute.