Ms Josephine Feehily:

Our code of practice sets out how we interpret the legislation and how we will apply it in particular circumstances. Again, I have to say that in almost all cases we do apply interest and in almost all cases it is properly recorded. This particular one was unusual. We have to accept an argument back - a sterile argument about interest in a context of a case where there was a judgment point about when was the transaction properly taxable. Interest is not really the issue. The issue is getting the transaction properly accounted for and collecting the tax. If we were driven by interest as one our performance measures, it might not be the best kind of message to give to our officers. We need to be careful about driving too hard a notion that interest is an end in itself all of the time. We have to be prepared to listen to a submission, and we do, but we do not do it that often. This case was particularly unusual.