Mr. Niall Cody:

We have issued comprehensive guidance, though various people are not happy with all of it as it relates to some of these issues we discussed earlier.

We set out the guidance on how the rules apply, reflecting the case law, and it is available for everybody. The challenge is that people in certain circumstances would like it to be wider but, if it is to be wider, legislation has to be enacted to make it wider. We have reflected the case law in our guidance and we have reviewed it, following the Appeal Commissioners. We discussed it at the tax administration liaison committee with the various tax practitioners, the Irish Tax Institute, the accountancy bodies and the Law Society. They asked us specifically whether we were changing our guidance and we said we were not and that we were satisfied with our guidance. That does not stop individuals claiming, and it then becomes a matter for the courts.