Ms Sabha Greene:

We are still at a very early stage in trying to work out the impact of all of this and how it will work in practice if it is adopted. It is very complicated. It takes some tax ideas and it has many hallmarks of a tax instrument. It speaks about a list of non-co-operative tax jurisdictions. It uses the word "turnover", which means different things in accounting and tax. It mixes in concepts of residency. Many people have argued it is a tax instrument and should be dealt with as such. It has come to us as a company law issue, so we must engage with it on this basis. We are dealing very closely with the Department of Finance. It is possible that the Council could decide to move it into the realm of tax, but this has not happened. I do not know how likely it is. It is very hard to say. I cannot emphasise enough how early it is for all 28 member states, which are still grappling with it.

The Commission would argue this is an important issue for small and medium-sized enterprises because they are not in a position to take advantage of paying tax in different jurisdictions in the way multinationals are. I do not advocate one way or another, I am just stating the background. It states these companies already have to produce this information for tax authorities so there is no additional burden in making it public. One could see it both ways. I am sorry not to come down on one side or the other, but there is so much in it that looks like a tax instrument while at the same time it does look like a financial reporting instrument.