Mr. Niall Cody:

The only point I would make is that the concept of the arm's-length principle asserts that inter-group transfer prices should be equivalent to those that would be charged between independent persons dealing at arm's length in otherwise similar circumstances. Transfer pricing is an essential part of how transactions between groups are priced and the key is that these transactions are at arm's length. That is the process. Mr. Hession set out very well the overall context of the Coffey review and the policy changes required.