Mr. Ronan Hession:

Within the European Union. It is still relevant for transactions outside the European Union but, as Ms Kate Levey said earlier, there are essentially two philosophies now emerging, the first being the OECD arm's-length principle, which until now has been the epitome of the OECD's tax philosophy and the international standard for how transactions between groups should be taxed, and the second being formulary apportionment, which is under CCCTB. That is obviously a big step. All EU member states but one are at the OECD table and signed up to the arm's-length principle. This is an extremely technical area. Introducing formulary apportionment would not be a complete replacement because the other arrangement would still operate for third countries. That additional technical complexity could be an issue in itself.