Mr. Ronan Hession:

There is a significant portion of the directive that deals with tackling tax avoidance. The point I was making earlier, which is not a criticism of the proposal, is that many of the measures were already in the anti-tax avoidance directive. Their implementation is not contingent on this proposal. The Commission can speak for itself but I guess it would say that agreeing a common base with common rules brings greater simplicity and transparency and, therefore, less opportunity for arbitrage.

An open question from the Department's point of view concerns the fact that international tax co-operation on this goes far beyond EU borders. The OECD inclusive framework now includes approximately 100 countries so we are dealing with everywhere, including North America, South America, Africa and the Far East. We are reminded of how small Europe is when we go to the meetings. Much of the tax planning that has become notorious is not purely within EU borders. The OECD reports were trying, in a very meticulous and surgical way, to identify the various weaknesses that existed and to find very targeted measures to shut them down. There was an amazing amount of international consensus on that. We would always have a concern if doing something different or new at EU level were in some way to slow down the momentum of those reforms. That is something of which we would be mindful.