Mr. Niall Cody:

The issue with increasing the random audit programme is the huge opportunity cost. Our colleagues in the Danish revenue authority, which has focused very much on tax gap analysis and audit gap analysis, carried out 10,000 random audits. They practically stopped their risk-based audits in one year in three to try to assess it. We are not convinced that is the best use of what are scarce resources. It is also a huge burden and cost on business. We think the random audit programme provides a useful measure but are yet to be convinced that Ireland and Revenue, moving to full tax-gap, outcome-based measurement, will add to the work we do. There are also a number of other examples. The European Commission does a VAT gap analysis across the 27 member states although there are a couple of countries that have not been able to provide statistics. Other measures are available.