Ms Kate Levey:

That is fair to say. The principal tax authority is the country in which the parent of the group is resident. In addition, if the parent is ultimately outside the EU, the group members within the CCTB can nominate a group that would be the head for those purposes. Therefore, potentially more than those 50 taxpayers about which we spoke are located in a particular member state, but the Deputy is right that the formulary apportionment basically means that there are different factors now determining where tax is paid.