Mr. Niall Cody:

I hesitate to get into the details of the case for a number of reasons. It is useful to talk a little about the process we are in at present. As I set out, Ireland has put a detailed legal case in response to the decision of the European Commission. That is lodged with the court. It is not a public document. It has not been made public yet. The court effectively is in possession of that. It will publish summary legal pleadings in the official journal. What I read into the record earlier that the Department of Finance published is a summary of what will be published. That is all that will be published. We are in a situation here where a case is being made by the Commission in which there is a considerable amount of public detail available on the record, but obviously redacted. There is an answering legal documentation, which is not on the record and on which my legal advice is that I cannot put it on the record, apart from in the court. We have a process in train that will ultimately be determined by the court. I have no difficulty coming before the committee to try to answer as much as I can but I have strong legal advice and I do not wish to do damage to the legal proceedings that are in train. Going into the basis of Ireland's answer and rebuttal to the particular points made by the Commission brings us straight into that area. What I would like to do is, as much as possible, talk about what we do when we are trying to tax the branches of multinationals in Ireland.