Ms Cora O'Brien:

I agree with Professor Stewart. I do not believe the $100 billion about which we are talking would automatically come to Ireland if we were to change the rules. The way to stay ahead of the curve is to decide now how we can be attractive to these companies in a post-BEPS environment, taking account of the reputational aspects we wish to protect.

I go back to this idea that it is the rate and the regime. How are we going to structure our regime - just as other countries are structuring their regimes - to be an attractive place in order that if multinationals restructure in the aftermath of the base erosion and profit shifting, BEPS, exercise, the benefit of some of those activities and some of that substance will come to Ireland and not go somewhere else? The United Kingdom changed its rules on incorporation and specifically introduced a patent box because it was not getting any of this business and the authorities there could see it was very valuable business. In itself, that measure has issues because, as I stated, the European Commission is examining patent boxes. There is not an easy answer to it but we must be focused on trying to be competitive and it must be substance-based. This will be the environment that will exist when BEPS is over. We are in a good place because we have the fundamental principles for a substance-based environment. We simply need to make sure that our offering, particularly around intellectual property and digital companies, is competitive. Multinationals like this.