Ms Josephine Feehily:

There will be if the person does not pay when the appeals are finally resolved. There is also a real risk that it will not be there. That is a matter of some concerns to us.

The Deputy might or might not be aware the Minister for Finance announced in his budget speech that there would be a consultation on the reform of the appeal system.

This consultation is under way. We made a submission, which we published, and drew attention to some of our concerns about the money. We suggested it might be time to consider whether we could collect some of the tax as the appeal goes on. The practice and legal position has been to wait until it is finally determined. There are a number of options one could examine, such as at the end of each stage the person pays or we repay depending on who wins. Alternatively with regard to VAT the trend in Europe is that it needs to be paid while the appeal is being handled.