Mr. Eamonn O'Dea:

Revenue's function in terms of advance opinions is primarily to clarify the tax treatment of a proposed transaction or business activity under the applicable legislation and thereby enable companies to get their taxes right. By and large, we do not address hypothetical arrangements or transactions. One of the principal issues we might address in advance of a company definitively commencing business here might involve inquiring as to whether its activities would constitute trading. That might be an example of a company approaching us in advance of starting up. Multinationals do not tend to come to Revenue to seek approval, an opinion or a ruling on structures they might have put in place which are not actually part of the Irish tax code and have been brought into question. When multinationals put such arrangements in place, they usually take account of the laws of various jurisdictions. Such structures would not be specific to Ireland. We do not offer such structures as part of our code. Certainly, we would not be addressing that kind of issue in advance of a company arriving here.