Mr. Niall Cody:

It is about looking at the different tax rates on income versus capital gains and corporation tax and engaging in tax planning to minimise the tax paid while maximising the benefits. We have identified the national case base below the level of large cases division. A dedicated resource is involved in profiling the cases because the challenge is to focus on the non-compliant while not disrupting the compliant taxpayer. Two years ago, I was asked why we were not on top of things and I explained that we were like the people working against doping in sport. If we come across something that is serious we can go back to it We can go back four years in an ordinary case but longer where there are serious evasions. It is a bit like the information on offshore accounts. We will find people, even if we do not do so immediately, because our data matching will improve.

We are trying to improve our knowledge of the sectors which can do this type of stuff. Anybody who moves beyond planning and becomes engaged in abusive practice is better off coming to us before we come to them. In the chapter of the report of the Comptroller and Auditor General on medical consultants it shows how, in the original cases at which we looked, the taxpayers did not avail of the opportunity for a disclosure. They and their advisers had felt that what they were doing was unchallengeable. I was in Philip Brennan's office at an early stage when it was not clear that we would win these cases. He happened to have a letter from one of the agents on his desk, with a comprehensive rebuttal of everything we were trying to do. There was an element in the letter of a tone which meant "the cheek of ye, challenging the schemes we have set out" but we follow these things through to the end.