Mr. Niall Cody:

The arm's-length principle is the methodology around transfer pricing. What it is trying to do is get a market rate for transactions between intergroup transfers. It is trying to say that if one is buying on the market independently, that is the benchmark to mark against. That is the arm's-length principle. Again, the Commissioner said on Tuesday that is the secondary part of the Commission's case. That is the alternative argument. In some of the commentary and the talk about not applying arm's-length principles, the arm's-length principle and transfer pricing rules have evolved over the last number of years. There were guidelines in 2010 implemented in our law. Clearly, they were not in place in either of the years. A number of commentators have highlighted that. In fairness to the Commission, however, that is not the core of its case. The Commissioner very much said that. It is the secondary part of the Commission's case.