Mr. Niall Cody:

Research and development is one of the big areas and double tax relief is another. I have no wish to mislead the committee; there are other views. Figures are bandied about relating to effective rates of 2%, but they are comparing tax paid in Ireland in respect of profits attributable to Ireland plus other parts of a company's activities. However, we cannot tax on that basis.

There have been a raft of developments - and there will continue to be - on base erosion and profit shifting as well as developments at OECD level. The Minister published his roadmap on tax competitiveness in the budget last year. The international corporate tax debate has been significant in the past two years and this will continue to be the case in the coming period as the base erosion and profit shifting proposals start to see the light of day. We will see debates about what will be implemented or otherwise. We are very clear and the Minister has been very clear that Ireland has a broad base with a 12.5% rate. We do not do tax rulings. We have a transparent system. Other countries sometimes have a different perspective.