Mr. Ronan Hession:

I do not see how that would be the case. It may be that there would be more competition between the European offices of the big four firms. I refer to a common knowledge pool. When the OECD published the BEPS report, it issued its own questions and answers and addressed formulary apportionment, which is the mechanism used on the CCCTB. It made the point that we do not know what the tax planning opportunities would be under that. Certainly, it is possible to criticise the existing system because there is no tax planning around it. It is untested. I said earlier that I would be surprised if a common base were impenetrable in respect of tax planning.

It is worth bearing in mind that the issue of advisers, etc., is the subject of a separate initiative at EU level in terms of mandatory disclosure of tax planning regimes. Ireland is one of the few countries that has that already domestically. We have already been supported in principle in that. Separate to the way companies pay tax or the way governments behave in a tax base, the role of advisers is up for discussion. That derives from action 13 of the BEPS report. There is more to be said there in terms of how they behave. I do not believe it is necessarily a point that the Commission has identified in favour of the CCCTB. One could infer from its belief that it reduces compliance costs that it envisages a lesser role for tax advisers, but I am putting words in its mouth somewhat in that regard.