Michael McGrath (Cork South Central, Fianna Fail)
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On the attribution of the base between the different member states, under the Commission's proposals it is one third, one third, one third in terms of the weighting between where the sales happened, the staff are located and where a company's assets are. The Irish Tax Institute made the point in its opening statement that this will be an arbitrary formula to allocate profit rather than the arm's length basis agreed locally only last year. Will Ms Cora O'Brien clarify what the difference will be? How will that compare with what was agreed at OECD level in terms of the arm's length arrangements for allocation of profits? What is the key difference?