Mr. Niall Cody:

I talked to the Senator about the guidelines. An opinion applies up to the time it is either withdrawn, the facts and circumstances change or the legislation that applies to it changes. If the legislation changes, the rulings do not have any further value. It is purely up to the company to come back to us and say that in the context of the changes in whatever section it is in the Finance Act, it is now looking at how this applies. We do not go and say "Lads, the law has changed now and that is gone," because the law is changed, it is gone and it is a self-assessment tax system. The company and any taxpayer are still obliged to return their tax having regard to the self-assessment system. If the legislation changes, the previous ruling could not apply.