Ms Josephine Feehily:

A system could be introduced whereby at the end of each appeal, because there are several, one party, which could be us if we lose, repays so the tax is resolved at each stage. A system could be introduced whereby we look for security in the appropriate cases if there were a risk of dissipation. We do not have the legal framework for this at present. There is a process and consultation under way where these can be discussed.