Mr. Niall Cody:

Traditionally, international tax developments moved at a glacial pace, because at EU level, tax is one of the areas that requires unanimity. A country, or a few countries, can stop progress. The European Commission and some countries would like to see moves, but it is a national competence. What is surprising is that the OECD process has been very quick. It is a two-year process involving international tax across a vast array of processes. The speed and pace have been unprecedented but nothing is finished.

When all the reports are there, there will be certain aspects because it has a huge political dimension. The G20 and G7 have pinned their collars to some aspects of it. I am absolutely certain there will be change, but I am also certain it will not cover everything that is being discussed. At the end of it all, I would be hopeful that Ireland's position will be strengthened. All aspects of the tax community in Ireland have been fairly positively put forward in this area.