Professor Jim Stewart:

One possible solution would be to introduce a withholding tax. The Deputy may be familiar with the strategy called the Dutch sandwich, whereby profits were routed to a Netherlands-based company. The strategy was designed to get around that withholding tax royalty payments from Ireland. Subsequently the Revenue issued a directive that royalty payments did not have to be withheld from payments from Ireland. However, withholding taxes can create their own difficulties and tax treaties may make it very difficult to introduce withholding taxes. It is an area that could be examined as a means of raising tax revenue and perhaps it might be an option.