Mr. Gerry Smyth:

That is correct. There could be a range. Many of these cases will be settled before they go near an appeal hearing. When it is not possible to reach agreement, some third party has to make a decision on it. This is the Appeal Commissioners. I would not expect a case such as this to take very long to be decided or that there would be a delay. Delays tend to arise in higher value cases and in tax avoidance cases in which a person will go to the Appeal Commissioners because it is the first stage, but there are other stages afterwards. The last very big, high-profile tax avoidance case that was heard by the Supreme Court was in 2011. I can speak of it because it was a reported case. In that case, the transactions took place in 1991. It took 20 years before it was completed. The Deputy is correct. In the small cases, there is no reason why it should take a long time. However, in the big ones, where big money is at stake, those kind of-----