Dr. Brian Keegan:

Cross-border arrangements. Second, while this is a generalisation, I think it is a fair one. The emphasis on Irish tax law in recent years has moved away from companies being resident by virtue of where they are centrally managed and controlled to the default position being that they are taxable by virtue of their place of incorporation, which is here. The rule involving central management control is still very important in the context of our dealings with businesses in double taxation treaty countries but the general taxing rule is considerably tighter now than it was five years ago.