Mr. Seamus Coffey:

If the companies do not respond and continue to make those payments, they would not get them as a deduction. Those are huge payments, with the latest figures for 2017 showing that outgoing royalty payments are over €70 billion. The Deputy can guess that the vast majority of those are made to low or no-tax jurisdictions, where the companies do not have substance. This is in compliance with existing transfer pricing rules, looking at the substance we have, but the new rules indicate we should look at the substance of the receiver. If the companies did not respond and continued to make those payments, there would be a surge in profits in Ireland. It is fair to say companies will respond.