Ms Josephine Feehily:

The Deputy is putting words, sentences, to me which appear to be an opinion. I cannot reject an opinion, so I am not rejecting something I have not seen. My assurance to the committee is that we followed through on every piece of paper, piece of information or document received from the authorised officer and his various Ministers down the years and it was examined and followed through. That is what I am saying to the committee and obviously today, to the authorised officer. I am not making a judgment on his view because I am not in a position to do that. I would have to also remind the committee that this happened a long time ago. Revenue's powers, Revenue's orientation, Revenue's organisation has changed fundamentally since the mid-1990s in terms of prosecution and in terms of our focus on prosecution. The fact of the matter is that the law provides a ten year rule for us. I am also advised that in terms of regulatory law and white collar law, for want of a better word, that this is actually quite high.

Ten years would be normal, or occasionally, shorter periods. It is not exceptional in common law to have those kinds of ten-year rules, even if they were not written into the taxes Acts. That was where we found ourselves - in a position where the law was an impediment.