Mr. Niall Cody:

It is used a good bit. It underwent a significant rewrite in 2014 or 2015. We did a huge rewrite because it was originally constructed in such a way that we had to form an opinion and issue a notice of opinion. We found ourselves seriously challenged, not in the appeals process but through judicial reviews. There were some serious judicial review cases which challenged the process and sought to find out who formed the opinion. There was a High Court case which really came down to the meaning of the word "immediately" because once we formed the opinion, we were to issue it immediately. We were seriously challenged in the High Court and we were very successful in contesting those judicial reviews. In 2014, we put forward proposals to the Department and the Minister to revamp the general anti-avoidance provision.