Mr. Niall Cody:

It might be useful to broaden this to describe our approach to tackling anti-avoidance. We have three dedicated branches dealing with anti-avoidance in our large cases division. It is considering schemes that come to light through its own analysis of our databases.

It also looks at schemes which come to light through protected disclosures. There are different rules and different incentives, depending on what the taxpayer does. I spoke earlier about one of the key features which differentiates between tax avoidance and tax evasion, which is the idea of producing information. That is to say, whether the taxpayer gives Revenue the information and says that he or she is happy that it is legitimate and for bona fide business reasons, namely, to generate profit or whatever. We look at those. There are essentially two approaches to dealing with something which we see as having the hallmarks of avoidance. The first is to consider whether there is a specific provision in our anti-avoidance legislation under which the scheme can be tackled or we have our general anti-avoidance provision, which was originally section 811 of the Taxes Consolidation Act 1997. I believe this provision was first introduced in 1988. Again, we were one of the first countries-----