Mr. Niall Cody:

The legislation is based on EU and OECD standards. What we have tried to do is improve our guidance as we come across new insights.

I was asked a few years ago here could we not pre-approve every R&D claim because that would provide great certainty. The mantra in tax is certainty. It is really important. When we teased it out, we came to the conclusion that if we did that we would stop all research and development taking place because you would have to have the experts in at the start and there are not even that many experts there.

I suppose some of the research and development is very clearly cutting edge - totally new. Others are enhancements and development of the system. It is a really important piece of the Irish investment situation and the Irish tax code. It is set out in legislation and we have to deal with it.