Mr. Niall Cody:

I am tempted to say they are the Commission's words. They are not our words. We do not agree with or accept them. Ultimately, the Commission is saying that all the profits attributable to the two Irish-registered non-resident companies were properly taxable in Ireland. It is like two parallel lines. The Commission says that the profits of the companies are fully attributable and fully taxable in Ireland. We are saying, and Irish law says, that the profits of the branch are taxable in Ireland at 12.5%. The debate could go on forever and, ultimately, it will be a matter for the courts to determine. Revenue can only apply the Irish tax code. We cannot apply the Irish tax code as people might want it to be. Our role and responsibility involves applying the Irish tax code. The Commission is clearly of the view that the profits are fully attributable and that is where the figure of €13 billion comes from. Ultimately, it is a figure by 12.5% - there or thereabouts. If, from the Commission's perspective, that figure is the amount of tax paid plus €13 billion and is what should have been paid, it then uses the word.