Mr. Seamus Coffey:

I agree with much of what Ms O'Brien and the Tax Institute have just said. When it comes to the international debate on tax avoidance, one of the most serious issues is the ability of companies to declare large profits in jurisdictions in which they simply have no substance. This is definitely not the case in Ireland and clearly not in the EU as many of the companies have substance and operations here. One of the key underpinnings of the measures and proposals at international level led by the OECD is to try to correct this issue of companies recording significant profits where they have no substance. Some of the proposals regarding permanent establishment and reforms of transfer pricing go about addressing that, but the CCCTB proposal does not address it because it happens somewhere else. It is going in the opposite direction to trying in a sense to amend and update the current system, which clearly has not taken pace with the change in the international economy. It is part of the global corporate tax avoidance debate but it could be missing some of the key points.