Mr. Niall Cody:

No, but there is no doubt it is in the background. It is part of the environment in which we are operating. One of the things the Commission makes a play of is that the tax adviser mentioned employees and there is an inference that we were influenced by the idea that this is about jobs. We want to make very clear that we are only interested in the issues that are relevant to the calculation of the tax. The opinion updated that. We changed it in 2016. The 2016 changes relate to the Apple case in that we reduced the period to five years from seven and undertook to publish the numbers in our annual report. The other thing that happened in the meantime is the move to country-by-country reporting and the exchange of information. If we give an opinion to a multinational entity which has an impact on the tax arrangements in another country, we will exchange the information with the other country. It touches on an element of what Deputy Boyd Barrett was saying. There will now be greater knowledge of the full pieces of the jigsaw. Every revenue authority should have a view of the issues relevant to the entire group because there is no doubt multinational corporations have oversight of all their own operations and, in many cases, they structure them in such a way to minimise the tax. There is no overarching tax authority looking at this. The individual administrations will have relevant pieces which from country A's point of view is very valid and protects its tax base but country B might say it has an impact on theirs and they want to revisit it. That is part of the backdrop.