Michael McGrath (Cork South Central, Fianna Fail) | Oireachtas source

In terms of the ability of a large multinational to design its corporate tax structure and engineer its affairs in a manner whereby profits can be moved along the chain to end up in a country where no tax is paid, let us say a true tax haven, is there still too much flexibility through the royalty payment process where there is no underlying economic rationale for the transfer pricing arrangements or is there a consistency through the arm's length principle and OECD standards as regards what determines how transfer pricing works? It seems that profits have been shifted to end up in the Caymans, Bermuda or other places where no tax is paid.