Mr. Niall Cody:

If they are managed and controlled outside of Ireland, Irish tax rules apply. This goes to the heart of things around "double Irish" and the Minister has made changes in legislation over the last number of years as part of the base erosion and profit shifting, BEPS, process. The residence rules and the mismatch between US rules and Irish rules is the cause of this problem.

There is tax planning by multinationals that exploits the mismatches. It does not make Ireland responsible and we can only implement the Irish tax rules.