Mr. Brian Keegan:

Yes. It contains a fail-safe provision in that it is only available in the context of a company whose ultimate parent has a tax treaty with Ireland. It may not be paying tax in Ireland but it is accountable in a country we know we can deal with, and that is important.

In terms of property, the only observation I would make is that there is a long-standing position in Irish tax law that any asset which derives value from land or property in the State is prima facietaxable in the State. It appears to me that section 110 vehicles, at least in so far as they have been hitting the news in recent months, seemed to-----