Mr. Gerard Moran:

It would be extremely challenging to introduce such a tax in 2017. It is very important to nail down the precise scope of the tax in terms of what would and would not be covered by it and to put in place a regulatory regime around all of that to ensure compliance and protect traders who are compliant from unfair competition. An overriding concern would be that we could fall out of step with what the authorities in the United Kingdom are doing. Our working assumption is that if one were to introduce a tax on sugar sweetened drinks, it would need to be at a material level to have an impact. If it is at a material level, one is looking at potentially significant discrepancies between here and the North of Ireland. That would give rise to obvious compliance problems, which would be extremely difficult to deal with in the context of the Single Market. Both countries are still in the Single Market and one cannot have border controls or checks on movement in it.

Essentially it would in all probability be a self-assessed tax where returns are made on the first supply in the State of the products that are liable to the tax. There would be a big concern that if there was a significant difference in price levels between here and the North, there would be diversion. I am not talking about consumers going up to buy soft drinks but a grey market could develop with illicit supplies in bulk going into the retail sector. That would be a very difficult challenge. There are several compliance risks and practical considerations in the design of the tax that in our view, from a tax administration perspective, suggest that 2018 would be a preferable date.