Mr. Mike Lewis:

At the risk of there being an alarming degree of unanimity on this side of the table, we said in our opening statement and in the report we put out in November that there were elements of the existing OECD-BEPS package which could help in this area, in particular around some of the aspects of the multilateral instruments in relation to which Ireland continues to reserve its position. I highlight to the committee the fact that Ireland has reserved its position on article 12 of the OECD's multilateral instrument, which is supposed to deal with some of the situations in which companies do not have a bricks and mortar presence in a jurisdiction but are nonetheless doing business there. The Department of Finance's justification for reserving judgment on that part of the instrument was that it was waiting for the OECD to report back on some aspects of profit allocation to permanent establishments. The OECD has now reported back after the inclusive framework considered the matter and it would be good to get some sense of whether the Government is now ready to sign up to the article given that it is relevant to the digital discussion.