Mr. Martin Shanahan:

I thank Deputy Deasy for those questions. To start with, I will comment on our overall competitiveness and tax, and, if there are other questions, on competitiveness.

Ireland's competitiveness has improved dramatically in the past number of years. It declined dramatically in the 2000s and it was more challenging to attract foreign direct investment as a result. Costs were too high. Resources were being supplied to areas which were unsustainable. Obviously, we know what the result of that was. Our competitiveness has now improved. I would say that, at all costs, we need to protect our competitiveness.

Our competitiveness is not just around taxation. There is probably, in the international debate and sometimes in the Irish debate, an undue emphasis on taxation in that competitiveness is about everything. It is about the costs, infrastructure, the availability of talent, the attractiveness of the locations to which we are trying to bring companies, etc. All of the international rankings, as I said in my opening statement, show that Ireland's competitiveness is improving. The difficulty with international rankings is that they typically lag and they are telling one something after the fact, and we need to be mindful and ensure that they continue to increase and that we stay there.

In relation to the changes that were made in the 2015 budget regarding tax, first, the changes to the residency rules that Deputy Deasy is referring to were not made in isolation. They were made in a context where other parts of our tax code were improved, particularly - I mentioned some of them in my opening statement in relation to the amortisation of intellectual property - in relation to SARP and, indeed, to personal taxation rates. Obviously, the budget also announced that the Government intended to introduce a knowledge development box. I would put all of those in the plus category of making Ireland more attractive to foreign direct investment.

In relation to the change to residency rules, I believe that over the long period that will also be a positive because it was something that was being used to point to Ireland, and causing damage to our international reputation. The change was well handled. We had engagement with our clients prior to the changes in the run up to the budget - obviously, nobody knows what the changes will be until budget day but we obviously plan for all eventualities. Once the budget was announced, we had engagement with our clients about it. I wrote to every client of IDA Ireland on the day the budget was announced. We followed that up with engagements through all of our executives on the ground in market, at corporate and in Ireland, and we also had a number of investment marketing missions directly after the budgetary process in order to speak to our clients directly in market.

There are a number of ways one gauges what the impact will be over time. First, one speaks to the clients and asks them what their response is, and for the most part that response has been positive. It is not universally positive, as Deputy Deasy would expect, but for the most part it has been positive.

It impacts on different IDA Ireland client companies in different ways. There is a small number who may have availed of structures. They now have to find an alternative to that structure. For those that are operating already, they have over six years in which to do that from the point it was announced. There are those who may have believed that the existence of such structures was doing damage to Ireland's reputation and was causing them a difficulty in terms of their investment in Ireland, and would have very much welcomed the changes. There are those for whom this has no bearing at all, which would be a large part of the portfolio, including emerging companies who are still in ramp-up stage and for whom tax does not feature. There is a whole-----