Mr. Ronan Hession:

Yes. When one looks at the analysis and the number of countries where the graph is below the x-axis compared with those where it is above, it is difficult to see where the momentum will come for an agreement. Essentially, members states will be surrendering significant portions of their base in service of an abstract principle unless they feel that there is some greater motive at stake - in this case, if they feel it is necessary to weed out tax avoidance and this was the only way to do it. What compromises that argument is that the anti-tax avoidance elements of this directive have already been agreed. Therefore, having agreed to the anti-tax avoidance directive, we could not argue that those elements bring subsidiarity because we have already gone as far as signing up to that. Carrying them in here bolsters the characterisation of this directive as being an anti-tax avoidance one. However, in terms of additional added value it is difficult to see it based on those components, aside from what I have already said about a common base making it more transparent. Having common rules flushes out what would otherwise be tax avoidance schemes and arbitrage between differences.