Mr. Charlie Phelan:

In fairness, I must state again that the tax system in Ireland is self-assessment, be it capital acquisitions tax, capital gains tax or income tax. By and large, what is sent in to us is accepted as it is. We engage in some inquiries relating to some transactions. We do not give a rubber stamp to everything that is submitted and say it is perfect. If we were to do that, we would have to examine every transaction included. Self-assessment means self-assessment. While one might say that we have accepted this stuff and we knew it all along, the fact is that this is the self-assessed tax people made and they put their valuations on it. During 2015 and 2016 we started to look at those valuations and found some difficulties in that area.

I will turn to the points the Deputy raised in his initial questions. He asked how many more farmers are affected. We do not know the extent of the patronage shares issue. We know it in the Kerry situation but we do not know it in the rest of the co-operative movement. However, if there is an issue for other people this is an opportunity to come forward if there is a liability. Perhaps if the technical case is heard as a test case it will put the technical point straight, once and for all, as to whether the Revenue Commissioners are correct or incorrect in this regard. That is certainly an advantage of having the case heard. In the case of Kerry, we understand that 3,400 people got patronage shares, as the Deputy mentioned.

As regards the value we put on the shares, when shares are transferred between unconnected parties, and I believe perhaps even between connected parties, they go through the board meeting to be authorised. They also go through our stamping system to be stamped, so we have a database of the valuation that was paid for or put on the shares.

The other co-operatives have been mentioned. As to the level in the Revenue Commissioners organisation where the decision was taken, every day Revenue Commissioners officials throughout the country will make decisions on various compliance activities. We set out in our business plans every year the number of things we plan to do in the year. I am not quite sure what the Deputy means in referring to whether it was taken locally or nationally, but I can assure him that the Chairman of the Revenue Commissioners-----