Mr. Seamus Coffey:

I am not sure it would make a massive difference. I think a worldwide regime does mean that one has certain protections and one does not need the CFC rules. If we have a worldwide regime, then profits are taxed wherever they are earned. If they are taxed at a lower rate than our 12.5%, when the company brings the profits back to Ireland, we can top the tax bill up. The issue with the territorial system is that we are one of the few countries that maintain a worldwide regime. Over recent years, several of the other countries that had worldwide regimes have moved to territorial systems because of the improvements in CFC legislation. Now tax authorities can look at companies abroad and determine whether relationships are genuine or just being set up to move profits abroad. I do not think it would make a huge difference. Our worldwide regime possibly adds to our reputation because as soon as a company is resident here, it is taxable on its worldwide income. However, it is down to the complexity of undertaking the foreign tax credit.