Mr. Niall Cody:

It is a very fine line. It is interesting that the first section 811 case took more than ten years to get through the whole process and ended up before the Supreme Court. We won that case. That was really important. A couple of weeks ago, there was a decision from the European Court of Justice on an Irish VAT case which centred on the concept of abuse of rights. This principle is similar to a general anti-avoidance provision. The case was about a transaction which took place in Cork in 2002. It went from a referral from the Irish courts to the European Court of Justice and a decision issued a couple of weeks ago. It was very much on the same issue. The whole purpose of the transaction was to get a whole load of VAT back and to not pay any.