Mr. Niall Cody:

The rulings that were given deal with a once-off transaction and only apply to a transaction. The rulings we are talking about in this case are how the profits are calculated for the branch. That continues until the facts and circumstances change. Part of the process we are engaged in is this idea that rulings now only have a life of five years.

We started pulling the shutters down on any ruling made before 2012 this year and issued new guidelines last weekend. If someone is relying on a ruling that is more than five years old, he or she needs to revert to us because it cannot be relied upon any longer.