Mr. Niall Cody:

If we do an audit of a taxpayer's records we engage with the taxpayer and their agent and if there is an issue around the interpretation of law, that is, as to whether something is taxable, there will be legal advice but it will be more likely to go through the courts process. In other audits we identify what we see as undeclared income and we would seek to assess the tax liability. If our evidence was good enough it may end up in a settlement process and tax, interest and penalties will be paid as part of the settlement. Some go to appeal and there are various stages of the appeals process. Some avoidance cases have gone through a process of judicial review in the High Court and the Supreme Court and then the appeal itself has to start. That will involve the Tax Appeals Commission and then it may go to the High Court. It could, potentially, go to the Supreme Court again and may even go to the ECJ. Most of our cases are settled, however, and do not end up being appealed. We publish our figures on this and we collect in the region of €500 million in tax settlements.