Mr. Ronan Hession:

I think, as Ms Levey said, from a Revenue point of view that is a bit of a headache in terms of how to run two parallel systems. We are also mindful of the fact that we are not just talking about international tax planning within Europe. There are still multifarious international tax systems that will remain in place and a lot of the tax planning that goes on is not necessarily within Europe, it takes place in other jurisdictions. Therefore, one has to live with a certain degree of complexity.

I understand the motive behind the Commission's proposal for a common base. It perhaps makes it more transparent and with consistent rules there is less scope for arbitrage. That may be the case but, if it were to come into being, I would be surprised if it was impenetrable to tax planning. As regards the administrative side or compliance cost, the Ernst & Young analysis felt those savings were overstated.