Mr. Brian Keegan:

Inevitably - as a result of human nature, if nothing else - it has made Revenue an awful lot more cautious. We have seen in recent times a number of changes to Revenue's procedures around advance opinions, most notably in the last few weeks where Revenue has time-bound future opinions and any opinions post-2012 to a period of five years. A sunset clause has been put in place. That, of itself, is not necessarily a bad thing. One of the other points that generally applies is that we do not rely terribly heavily on advance opinions in Ireland in comparison with other European countries because our tax system is fundamentally different. It is based on common law principles rather than civil law principles. Looking at the judgment, there is a mismatch there in the tradition of tax and perhaps a misunderstanding.

To respond directly to the Deputy's question, it is bound to have had an effect.