Mr. Niall Cody:

To come back to what I was talking to Deputy Marc MacSharry about, our job is to ensure the tax system is administrated in accordance with tax legislation. Our large cases division has responsibility for the financial services sector in its entirety. One of its jobs is dealing with section 110 companies. As Mr. Hession stated, when they were put in place, it really had to do with international securitisation; there was no risk to Irish taxation. We would keep an eye on what was happening and would have a very close relationship with the Central Bank on an operational level, subject to the legislation in place on the exchange of information. It was in that context that in 2015 we identified the issue of property transactions within section 110 companies. We started a process to look at their use for Irish property transactions. That process continued through 2015 and 2016 and led to changes in the legislation to target the amount mentioned. As Mr. Hession stated, some of the issues are related to the level of information we receive. Our powers in that regard were increased to ensure we had greater sight of what was going on. That work is continuing. It is the ongoing job of a tax administration system to constantly look at what is going on. Sometimes it will take us a while to get our heads around what we are seeing. It comes back to companies, advisers and practitioners looking at the legislation, as laid down, and what is happening in other countries and applying the provisions.