Mr. Niall Cody:

It is not a feature of the Irish tax system. We get challenges. There are disputes going on, and I have spoken about it at other committees. The success rate of our competent authority in disputes with other countries is very high. Ireland features very prominently in the multinational tax system - we are a significant player in foreign direct investment - and so there are disputes. The adjustments are reasonable, however, and it is not a big proportion of the profits attributed to Ireland. Ultimately, the company sets the transfer pricing arrangements. The arrangements are subject to review by Revenue and the other side. Some countries are very proactive in challenging. These take a number of years to wash through the system.