Mr. James Hickey:

The first challenge here is that the special purpose vehicles are specifically required as part of the section 481 tax incentive. In international practice, for example in the UK, every production has a special purpose vehicle.

This is not unique to Ireland as a particular way of doing business. Special purpose vehicles for the making of feature films and TV drama series have been in place. This is not something recent and it goes back 30, 40 and 50 years. It has been standard practice for a long time not just in Ireland, but throughout the rest of the world.

There are two separate issues. There are the employment arrangement issues on the one hand and the structures of the special purpose vehicle situation on the other. The special purpose vehicle situation was introduced specifically by the Revenue Commissioners in Ireland at its request. It was not something generated from the sector. Revenue wanted it for accounting purposes and clarity of lines, etc.