Ms Josephine Feehily:

There is not an arbitrariness, I hope. I hope there is a fairness. In a strange way, one of the assuring things about Chapter 27 is that all of the weaknesses in our processes were in favour of the taxpayer. I know that might sound strange but it would be much worse if they were the other way. There is a fairness. When an auditor has the taxpayer or the taxpayer's agent in front of them we have to give them some room to reach a settlement that they think is reasonable. They have statements of affairs available to them so they know the circumstances and we have to give them. That is our view.

As long as we make that same facility available to everybody - we do that by way of the code of practice - then there is a fairness in it-----