Mr. Seamus Coffey:

We would have to assess that but I do not think from a revenue perspective it should make a massive difference. We have a worldwide system that takes the income that Irish resident companies earn abroad and includes it in our tax base. The issue is that for almost all of that income, the companies have paid tax at more than 12.5% so there is no additional tax due in Ireland. It is a completely different situation from that prevailing in the US. It has a 35% rate and a similar system so there would be substantial additional tax due. There are certain issues around the size of the foreign tax credit being claimed. There are also issues around companies that have low effective tax rates of 0% or close to zero. A lot of those companies do not have substantial activities in Ireland and the income on which zero tax is being paid in Ireland is foreign income on which the companies have already paid tax. We would not necessarily be losing revenue if we were to move to a territorial system. However, we would have to be careful that companies did not move money out. That is why-----