Mr. Seamus Coffey:

Yes, there is no doubt it would be seen as changing some of the underlying parameters behind those investments. It would not change the overall amount of tax that should be paid. There are companies who would have moved their intangible assets here before 2015 when the 80% cap last applied, albeit that the vast majority of the claims currently being made are for intangible assets that came post-2015.

The extent to which such a change is seen as being in bad faith is hard to determine. The Deputy would have to ask the companies themselves that but the overall impact on their tax should not be huge. It should be a matter of timing unless it is expected that the tax will not be paid when the capital allowances run out.