Mr. Niall Cody:

I know the committee had the discussion with the Minister around the non-American profits. That is basically the case at its simplest. The Commission is saying it is fully taxable in Ireland. Irish tax law says the branch profits are taxable in Ireland - not what takes place outside Ireland. I am not anticipating the questions I will be asked but I know I will be asked about the headquarters. What is really important in the context of Irish tax law and what we must do is look at what takes place in the branch - not what takes place or what is outside the branch.