Mr. Sorley McCaughey:

On the capacity issue, Ireland and Irish Aid are commendably very focused on building capacity but could be criticised slightly for the kind of capacity building being done. It is capacity building within a particular paradigm that has perhaps developed without much input from developing countries. The capacity is being developed in order to implement solutions that are not particular to their needs. We would like to see greater policy space for developing countries to develop individual policy responses to the unique set of challenges each country faces in keeping revenue within that country. That kind of capacity building is at least as valuable, if not more valuable, to developing countries than building the capacity to implement the base erosion and profit shifting, BEPS, process, which those countries played very little part in developing.

In fairness to the revenue authority, the issue concerning Zambia was highlighted in response to a report published by Action Aid, which showed that a subsidiary company in the International Financial Services Centre, IFSC, was being used by a large multinational based in Zambia to shift profit out of Zambia into Ireland and on to further countries - tax havens - at a cost of approximately €8 million a year to the Zambian authority. The company based in the IFSC had no employees; it was a total swizz. Revenue here had not been aware of it but when it found out, it moved to renegotiate it with the Zambian authority.

This is an example of very effective advocacy on the part of a poorly resourced NGO. There is a question as to how Revenue did not know about that if a poorly resourced NGO could identify and bring it to light. That is not a great scenario. Similarly with our report, we highlighted the existence of the single malt structure, which got some profile. I am not sure if it is an entirely great situation whereby four days of poorly-paid researcher's time manages to identify that and we, as a State, are not identifying. There are some concerns in that regard. Dr. Killian will refer to the sustainable development goals, SDGs, and tax.