Mr. Niall Cody:

In general terms, transfer pricing is a core element of the international tax system, the arm's length principle and the rules that are set out. Capital allowances are also a common feature of the tax system. The idea of setting any value they like on their intellectual property and transfer pricing is actually not the position. They are bound to have arm's length principles set out and documentary evidence to support that. It is subject to review by tax authorities here and externally.

There is an issue with capital allowances and the placing onshore of intellectual property. I know that there was a discussion yesterday with Mr. Seamus Coffey about this feature of the tax system. There is a difference between it and transfer pricing, which is actually the rule. The aim is to ensure it is in accordance with the arm's length principle. Revenue seeks to ensure we review it and that we have a programme to review transfer pricing. The policy on capital allowances and whether the figure should be 100% or 80% are matters for the Minister.