Ms Cora O'Brien:

I do not have the same insight into the data that Professor Stewart has because I have not done the detailed analysis, but it is a matter of fact that these companies under Irish tax residence rules are not managed and controlled in Ireland and do not have income that is attributable to Ireland. Under the rules we have, whether they are right or wrong or whether one likes them or does not like them, the income is not attributable to us and is not our income to tax. It might be in a jurisdiction that does have any tax or has a very low amount of tax but it does not mean it is ours and we cannot tax income under our tax rules that does not belong to us and is not attributable to us. I think that is the difference. Is that clear to the Deputy?