Ms Cora O'Brien:

I understand why Mr. Seamus Coffey has made that suggestion. When the cap was moved from 80% to 100%, it was at a time when a great deal of change was forecast in light of the OECD's base erosion and profit shifting, BEPS, proposal and positioning Ireland to deal with what would happen as a result. It is good that there has been a review of what happened. Many intangible assets have come onshore. In many ways, that is good. Under the new regime, IP and substance must be matched. The fact that we have IP is crystallising substance in Ireland in the rest of the business and protecting that for the medium term.

The number of claims is large. A cap of 80% would have a smoothing effect, so it is a reasonable recommendation to make, given the size of the IP that we now enjoy.