Mr. Ronan Hession:

I imagine that is probably what is coming through in the analysis. Let us consider the previous analysis and what we are seeing now. I have yet to see analysis suggesting that it is positive in terms of revenue, especially in terms of corporation tax. It is one of those files. We have had several EU files in the past year, as well as international tax proposals. We have discussed them in terms of tax principles and the correct design. To some extent, in this case it comes down to the money. What would the impact be on the base of a country like Ireland? Could Ireland afford it?

Having said that, we are having this conversation using data from other people. I am not suggesting that we have the right answer compared with others. However, we believe the onus is on those of us in the Department, along with our colleagues in Revenue, to undertake the analysis and put forward our figures. It goes different ways. Ms Levey made the point about how the treatment of research and development under the common base is in some ways less generous than it is now in Ireland. There is a net figure but there will be pluses and minuses within that. There will be negotiations and naturally, every country will arrive at the table seeking to push the elements favourable to it and to exclude other elements. What we have now is a starting point. What we have learned from experience is that there will be a process of negotiation. Obviously, we will have to box clever in that negotiation in terms of how we put across the Irish case.