Mr. Conor O'Brien:

The Deputy has identified an important point. I mentioned earlier that corporation tax can only be charged on the net profit arising to a company. It is well known that the classic kind of case we are talking about is a US multinational that places intellectual property, say, a brand or technology, into a tax haven - we will say Bermuda for the sake of argument. It then creates a factory in Ireland. The factory in Ireland does not own the intellectual property. It manufactures goods and sells them. Revenue from the sale of goods comes into Ireland and Ireland pays - I think this is what the Deputy is alluding to with the trade charges - royalties for the use of that intellectual property.