Mr. Brendan McDonagh:

If we look at the original state aid approval of NAMA back in March 2010, one of the concerns of the Commission was that NAMA should not distort the market, that we would have no unfair tax advantage and that we would operate on a tax-equivalent basis to any private sector entity. Therefore, when we had the SPVs, we set them up, taking tax advice, using section 110 structures. Obviously, that allowed us to pay smaller taxes up to 2016, the same as anybody else in the market. The tax changes in 2016 meant more taxes were paid and that is how we have ended up paying €450 million in tax to date. It is a zero-sum game because the money we paid in taxes would have been paid over to the Government in the form of dividends if we did not pay the taxes.