Professor Jim Stewart:

I do not agree with that because one change that BEPS could make is to decide that sales and profits arose where the cash was generated. In the case of the Internet-based companies, that is not in Ireland. If one is making profits in another country such as France or wherever, it then would make sense to move costs to that location. Consequently, it would make sense to hire people in France, on foot of which one could offset those costs against the profits. There could be implications for employment, PRSI and for the profits of the companies here, as well as value-added tax and other issues. Particularly in the digital age, many of these companies with the Europe, Middle East and Africa, EMEA, type of structure are vulnerable to relocating their activities, depending on what might come out of BEPS.