Mr. Ronan Hession:

If that were to be a material concern, when we do our domestic legislation, we are always designing it so that there are no monkey puzzles either side of the threshold, that people are not artificially trying to keep below a threshold. I expect if that vulnerability is in the directive and if the directive were to progress to agreement, that type of manipulation of business to get around the threshold would be addressed. We have similar rules about anti-fragmentation to ensure that groups do not separate themselves and keep themselves below the threshold. That is a reasonably common feature of tax codes that one would make sure that where a threshold bites at a particular point, that there is no way of laying around with the threshold artificially.