Mr. Niall Cody:

The basic system that applies under the tax code in Ireland is a self-assessment system. Companies complete corporation tax returns. Large companies also provide accounts and XBRL data for us. We take a risk-based approach. Ultimately, considering the types of entity with which we are involved, we know the companies and the countries in which the foreign tax is being paid and the rules that apply under double taxation agreements.

In an audit process we can look for proof, and we can also look under exchange with other countries for confirmation of amounts. Given the type of entities involved and the type of claim involved, first, the dividend income is declared. It comes from a particular country. The rules that apply in that country are very clear. The double tax agreements are very clear. The legislation is very clear. It would be one of the low-risk checks, and a very simply check to carry out, to confirm the rules were applied appropriately and the tax computations involved.

On the type of challenges we have in managing large multinational enterprises, the idea that any of them would make a false declaration, which is the context of the question, would not be the case because of all sorts of accounting rules and sets of accounts. Certainly, it is very easy for us to confirm the amounts, and we would do that as part of our ongoing risk approach on all cases.