Mr. Rónán Hession:

It is the controlled foreign company rule, which is the rule which prevents companies artificially moving profits to a lower tax jurisdiction. As I said, we are now required to introduce this rule. Policy makers should periodically explore - every generation if one likes - whether we have the right design for our system. Mr. Coffey has suggested that when introducing this rule, we should also look at the question of whether orienting our system differently to a territorial system would be a worthwhile change. It may not make that much difference in terms of the overall amount of tax paid here but as so many countries now have a territorial system - the US is now moving to this system - this may become the default design norm in tax systems and, therefore, it may make things easier for us in terms of moving internationally in the years ahead. This is an assessment we have to do in the Department next year. We are currently engaged in a consultation process, launched by the Minister on budget day, which runs until the end of January. These types of rules can be very complex and can depend on company structure. Broadly speaking, that is the explanation.