Mr. Seamus Coffey:

The potential impact is very large. Clearly our corporation tax receipts have surged in recent years. We can go back to 2014 when they were between €4 billion and €5 billion. On an underlying basis now, excluding Apple, they are close to €30 billion. It is an enormous amount of money. It is linked to changes in international rules at OECD level and, perhaps, changes in domestic rules in the US. This is very much about US companies and where they place their intellectual property. Up to six or seven years ago much of it would have been in no-tax jurisdictions, such as Bermuda and the Cayman Islands. The OECD rules changed, in that their IP had to go somewhere else because they had no substance there.

Many of these US companies had two locations to assess. They could bring the IP back to the US and the parent company, or bring it to where their international headquarters is, such as in Ireland. Some companies took their IP back to the US. Google and Facebook relocated their IP from those no-tax jurisdictions to the US. I should say these jurisdictions have no income tax. They do have indirect taxes as they have to fund their services but they do not do so through direct taxes. Other companies, particularly in manufacturing, moved their intellectual property to Ireland. We saw a position where we had the intellectual property of high-end manufacturing. The surge in profits linked to these two key elements saw the amount of profit and the amount of corporation tax collected here soar.