Mr. Seamus Coffey:

I am unsure on the impact it will have on revenue. That will depend on the second element of the Deputy's question, the behavioural impact on the multinationals. There is no doubt that it will change the practices of the multinationals. One of the guiding principles of the whole BEPS process has been to have a greater alignment of profit and substance. What many US multinationals, in particular, have been able to achieve is to have a large amount of their non-US profits routed to what are essentially cash box operations in small islands where they have no substance. The rules propose that such cash box operations should only get a return based on the funding that they provide. I refer to interest rates and return on capital, not on the actual profits the company generates, the substance of which happens elsewhere. There is no doubt that the companies will adjust. One change that we have seen some evidence of to date in Ireland is that they could move their intangible assets to Ireland simply because they already have the substance here. That could lead to an increase in tax revenues in Ireland. It will definitely lead to an increase in the gross profits declared in Ireland. It could have knock-on positive consequences for revenue. I do think a behavioural response will be seen. The impact on revenue is less clear but it could be positive.