Mr. Gary Tobin:

There are a number of aspects to the question. In the first instance, there are a number of tax structures in place. Effectively, the Deputy is referring to registered non-resident companies. The tax structures to which I refer are not, as I am sure the Deputy is fully aware, particularly a provision of Irish tax law. They are arrangements arrived at through the interaction of the tax systems of numerous different countries. In this situation, what we are seeing almost amounts to tax planning. This is what tax planning is all about. Such planning involves tax practitioners arbitraging between different countries' tax systems, trying to identify where the differences exist and evaluating whether they can be exploited. This is just one example of that. At present, the OECD is examining this area internationally through the base erosion and profiting shifting, BEPS, process. It has set a very aggressive timeframe in respect of the next 12 to 24 months. Once that happens, the question that will arise will relate to the likely response. For example, will the said response come at national or international level?