Mr. Ronan Hession:

It would seem so. There are other aspects we need to examine such as, for example, the research and development provision. The common base is different to the research and development tax credit. We think it would be less attractive for firms therefore there may not be as big a cost. The allowance for growth and investment is a new provision, which would be a tax cost. Our expectation is there would be a tax cost because this is significantly narrower.

In addition, it is difficult to forecast what will come out in the negotiations or the interplay between the different aspects of this proposal and other proposals already on the table. One of the difficulties, and the reason I said in my opening statement that we would not just reheat our previous analysis, is that we have already made many commitments at the OECD table and at EU level. For example, the anti-tax avoidance directive was agreed during the summer. The tax avoidance elements of the proposed CCCTB directive, broadly speaking, largely import the anti-tax avoidance directive. This includes the provisions on control for our company rules, on interest deductibility and on hybrids, to which I referred. There is a kind of interplay of all the different aspects so that it is difficult to make a net judgment but our expectation is that the base in the case of the CCCTB would be narrower than that in the CCTB.