Mr. Brian Keegan:

I will make two quick observations. I cannot understand the description of the OECD process as being opaque. I cannot think of any process I have encountered in which there was more consultation and which was more accessible to the institutions and the people involved. In terms of information overload as a consequence of BEPS, a common reporting standard has been developed. In fact, the Oireachtas passed legislation in the Finance Act which allows the Revenue Commissioners not to accept voluntary disclosures any more with regard to offshore assets because the quality of the information they are getting is so good. I have to disagree completely with the observations on the BEPS process.

As regards how the law should be applied, I will make one observation to Deputy D'Arcy. The Revenue Commissioners were not saying this is how section 25 works. They were saying that they had a calculation to carry out of the actual commercial amount which falls subject to Irish tax. That is the issue. They have to give those types of decisions in all types of circumstances, be they to multinationals or to a self-employed person who perhaps uses his car for private use and business. They constantly do this type of work and if we impede their capacity to clarify matters for taxpayers in any way, we are doing ourselves a disservice.