Mr. Fergal O'Brien:

The impacts on reputational risk are incredibly hard to quantify. We have seen this in previous challenges we have had in the Irish economy where we had international reputation risks. It is clear to us based on what we hear from our members and the degree to which this has been raised for Irish-owned and foreign direct investment companies in their international networks that there is a reputational risk here. The complications of extending legislation such as this to services would be substantially greater than for the goods issue. To the conversation we just had with Senator Higgins, there is an established labelling and coding mechanism for goods. That will not apply for services. Services are not labelled. It will be incredibly difficult for companies. We will have to tease through what we mean by a ban on services. Are we talking about imports, exports or what is the nature of any potential services restrictions? It would be substantially greater than the impact on cost. It will be incredibly difficult for corporates to identify what those services trades are. There will not be codes on their systems for the occupied territories, as an example.

We also have the whole challenge around where service value creation occurs, particularly in this modern world of remote working and hybrid working. We could have people living in one postcode area and working in a very different area. Where the value creation occurs will be incredibly difficult to determine. We do not know what the value in services trade is. Any assessment would depend on potential legislation, which we have not seen. However, the feedback we have got from members is that implementation challenges, the administrative and regulatory costs and the potential economic costs would be substantially greater than in relation to goods as set out in the heads of the Bill.