Mr. Niall Cody:

The process around how transfer pricing is controlled comes into play.

It is a multinational exercise. There is a whole range of transfer pricing auditing. The Coffey report suggested strengthening the resources in Revenue to deal with transfer pricing and strengthen the competent authority. One of the features of international tax is that there are inter-tax authority disputes around the proper attribution of profits, and there is a whole process around competent authorities engaging with each other. We deal with other tax administrations on the issue of the proper attribution of profits. This is a feature across the world. We look at transfer pricing auditing of companies based here to ensure that profits attributed to Ireland are not understated. Other tax administrations are looking at the Irish issue. There is engagement on correlative relief, mutual agreement procedures which deal with disputes around the challenges. One of the recommendations is that we should bolster our resources in this area. The transfer pricing Organisation for Economic Co-operation and Development, OECD, standard was introduced into legislation in 2010.