Mairéad Farrell (Galway West, Sinn Fein) | Oireachtas source

I noted in Dr. Stewart's opening statement a reference to the fact that section 110 firms may be regarded as tax neutral but can result in large tax losses in countries which receive interest payments. I am aware that one of the issues the domestic tax base erosion and profit shifting, BEPS, process of the OECD was intended to tackle was the risk of double non-taxation. Would it be fair to say that the use of section 110 gives rise to risks of double non-taxation?