Mr. Niall Cody:

We will find that these cases are avoidance cases that actually cross the line and have fallen down. They tend to be the avoidance cases that are not the HWIs but are dealt with in our HWI unit. In terms of some of the legislation around avoidance, I know the qualifying avoidance disclosure features in the chapter as well, which was a legislative provision to allow settlements to be made for avoidance before the changes. We made some significant proposals to the Department for changes in our anti-avoidance provisions because some of the avoidance practices were so off the radar that they would certainly move across the line. I was here last year talking about some of the medical consultants project. The Comptroller and Auditor General did a chapter on the medical consultants, which ended up with approximately 28 of those settlements being published, which means they are in that space to which I referred. Unfortunately, what happens in certain cases is that some practitioner comes up with a scheme and people sign up for it. We always say that if it is too good to be true, it is too good to be true. There is a load of litigation going on in that sphere, not involving the Revenue, where people have signed up for schemes that are just not right.