Mr. Niall Cody:

When we did our structural change back in 2017, we used to have a large cases division that dealt with large corporates and high-wealth individuals but the scale was too big. We reorganised and we have large corporates in one division and high-wealth individuals in another. All the wealthy residents plus non-residents with a significant presence in the country are dealt with by that division and it monitors activity. Everybody asks do we know how many times they are here. One of the interesting things is when Covid happened, we were looking at a situation where people were here at the time the lockdown happened. We brought in an administrative arrangement but it only applied until they left. It was really interesting that some representations would have been made but Covid is still there. We said, "If you are able to leave you cannot benefit from the concession the next time you are home." What that showed me was a real care in ensuring they do not fall foul of the 183-day rule because of the consequences. These things are very highly managed by people with significant advisers. I think people fully comply with the conditions because it is in their interest to do so.