Mr. Seamus Coffey:

The likelihood is something that is very difficult to assess. In part it is down to legislative changes, particularly in the US, which is inherently unpredictable. It is down to the profitability of some of the companies. It is also down to the decisions they might make about their intellectual property. Moving intellectual property is not something that is done on a regular basis. It is quite difficult. We have yet to see significant outflows of the intellectual property that is here. It began to arrive from 2015 on, with surges in 2019 and 2020, and it continues to be here.

It is the US tax system that generates these intellectual property assets. German, French, Japanese and Australian companies do not have the ability to place the international rights to their intellectual property in other countries. Their tax systems state they keep their international rights domestically. The US allowed them to leak out. Some of them have gone back but most have stayed external. Many of them are now in Ireland because it is where the companies have their substance. Would these companies choose to move the intellectual property back to the US? They would face a difficulty getting out of Ireland as we now have an exit tax, which is yet to be fully tested. There is also the ongoing instability in the US, and whether that is a regime they would choose to go back to remains to be seen.

The risks are huge because the revenues are huge. The revenues are close to €30 billion, but it is hard to place down and say this or that is likely to happen. In terms of changes in policy, late last week we had the G7 agreement that certain parts of pillar 2 would not apply to US companies. That was announced last Thursday. For Ireland, it does not seem that significant initially. It depends on EU implementation of our minimum top-up tax. That is in legislation and that legislation would need to be changed for companies not to pay that. It just highlights the uncertain policy environment in which all of us operate. Trying to identify the risks is the right thing to do but it is very difficult to do with any sort of precision.