Mr. Fergal O'Brien:

Again, from our understanding of the roles and functions of the CPA, which are quite broad in the draft Bill based on what we would have seen in the original straw man of the policy proposal, we believe it will bring additional complexity in terms of establishment.

We are talking about significant technological and administrative investment. We have no idea what the scale of investment will be but it will be very substantial. We can only go on the costs that were incurred in the UK in terms of a similar structure and the number of years it will take for those costs to be ultimately refunded from people making contributions to their pensions and the taxpayer. We would like to see these costs as efficient and curtailed as possible. If we can use some of the existing infrastructure of the State through Revenue in terms of the payroll and employer engagement that is already established then we fail to see why we would not do that. Obviously it would have resource implications for Revenue and we accept this but we would have to expect to get substantial economies of scale through Revenue collecting this, in the same way as it collects social insurance contributions on behalf of the Department of Social Protection. It is not as if Revenue does not already collect non-tax revenue contributions for other arms of the State. It is already happening in terms of PRSI and social insurance contributions. For us it would mean a more slimmed down CPA that would easier to establish and should have a quicker timeline, be administratively less complex and be cheaper for the State.