Mr. Seamus Coffey:

We have seen increased disputes between countries over the location of profits. In whose country are the profits located? There is likely to be an increased incidence of such disputes. The perspective of the taxpayers is that they would like certainty that the country in which they are operating and declaring their profits is, in a sense, supporting them. From an Irish perspective, the issue is the protection of our tax base. We do not want countries reaching in, grabbing profits from our tax base and taxing them in their jurisdiction.