Mr. Niall Cody:

Essentially, in the simplest terms, in a brass plate company there is no substance. Generally, with companies registered for corporation tax there is substance to them. The Irish system is based on ensuring substance. Foreign direct investment is all about increasing employment and having actual substance in Ireland. There are special rules in respect of incorporating companies and changes in Irish residency rules going back to 1999. The rules were introduced to try to prevent abuse of Irish companies by entities that have no presence or substance in Ireland.