Mr. Niall Cody:

Since the changes in 2014, the rules have been that all companies incorporated in Ireland are resident here unless they are resident, for tax purposes, in another country with which we have a double-tax agreement from 1 January 2015. That has been part of the process of change that took place in our whole international tax process. A foreign-incorporated company is tax-resident here if it is managed and controlled here. The rules are set out in legislation. There have been changes over the years that reflected policy changes and they are set out in the corporation tax code.