Mr. Niall Cody:

Tax planning and the exploitation of mismatches in rules are probably not even tax avoidance; it is essentially tax planning. Countries have their rules and where there are mismatches there are some opportunities for either double taxation or, as it is called, double non-taxation. In some cases companies end up paying tax on profits in both countries because of mismatches in rules but there is increasing international co-operation in this area and the Government has been to the forefront in implementing the BEPS action plan to try to ensure that Irish-based business is taxed in Ireland.