Mr. Niall Cody:

We regularly use the term "aggressive tax planning". We see that. The Oireachtas lays down the legislation and the intention of the legislation. There is tax planning and tax avoidance. It is a grey area and there is no clear line. We see certain practices as aggressive tax planning or aggressive tax avoidance. The practitioners involved in this area would not see it in that way at all. Ultimately, when we form a view that there is unacceptable tax avoidance, we will challenge individual cases. Ultimately, such cases will be a matter for the courts to decide.