Mr. Brian Keegan:

The Deputy is correct. The best way to answer this is by saying that the process is not nearly where it should be at the moment. However, it is still a work in progress and open consultations are ongoing at OECD level as to how branch profits should be attributed. To summarise, we are in a better position - not just in Ireland, but generally around the world - than we were four or five years ago, but it remains a work in progress and there is still capacity for profit shifting to take place. That is why the BEPS initiative continues to try to roll forward.