Mr. Niall Cody:

I am not saying that. Irish tax-resident companies are taxable on their worldwide profits. They may well be entitled to some credit for foreign tax. That is the difference. Irish non-resident entities are only taxable on their activity here because, if one takes the normal territoriality rules, they would be taxable on their profits in their own country. As a result of different rules in different countries, there are sometimes cracks and this is what happens. It is what happens in this case.