Introduction

Good morning ladies and gentlemen.

It's a pleasure to join you today and I would like to thank your President Vincent Sheridan and Chief Executive, Pat Costello for the invitation to address the Institute's conference. The theme – meeting the regulators and sharing perspectives – is one that I endorse wholeheartedly. For a long time now it's been Revenue's view – and indeed our practice – that we engage with our customers and particularly with representative bodies. I am convinced that the administration of the tax and customs system has improved considerably as a consequence of this engagement.

Today, I've been asked to give a Revenue view of topical developments in the tax system with particular reference to three broad areas:

• Easing the regulatory and compliance burden
• Working relationships between accountants, tax practitioners and Revenue including the latest state of play on the OECD Tax Intermediaries study and
• Developments at EU level including proposals regarding the Common Consolidated Corporate Tax Base.

Easing the Regulatory and Compliance Burden

Quite a few studies have examined the regulatory and compliance burden on business (particularly small business) in the last couple of years. ROS finds great favour in these studies and gets high marks for its contribution to reducing the administrative burden. That said, Revenue continues to feature as the regulatory body which imposes the most significant burden on business. So the first thing I need to assure you and your clients about is that reducing the burden on business is a priority for Revenue – and will continue to be so.

Strategy

As I'm sure you know Revenue has a strategic focus, indeed an integrated one, on both service and compliance. Part of that focus is on identifying and implementing initiatives to reduce the administrative burden associated with tax and customs regulation. Implementing these initiatives involves structural realignment of the Office, heavy investment in new systems and significant commitment to upskilling our staff. It increasingly also requires that we, as Civil Servants, become more and more commercially aware – aware of the challenges you face in business and sensitive to ways in which we can match our requirements to your commercial realities – without of course compromising either side.

Structure

By now you are all familiar with our changed organisational structure. The introduction of four geographic Revenue regions should have considerably reduced the number of offices with which you've had to interact.

I do appreciate that the introduction of the new structure was not without its problems. One area that challenged us all was that of the resolution of high-level interpretation queries. You told us it wasn't working and we have responded with the establishment of the new Regional Technical Service (RTS). It is early days but I'm convinced that RTS will vastly improve our responsiveness. It's an excellent example of us working together-the Guidelines to give effect to the RTS were finalised in consultation with practitioners like yourselves. At the latest count nearly 1200 practitioners and business taxpayers have registered for the secure email facility in the RTS. Over 300 queries were received up to the end of October and most of them have been advised on.

Our latest initiative on the structural side is to establish a single point of contact for employers with queries concerning the operation of PAYE. This one stop shop service, hosted from Nenagh, will come into operation on 30^th of November. It will be a readily accessible centre of expertise which will reduce compliance costs for employers and agents and eliminate the frustration of having to deal with multiple offices.

Systems: ROS

Everybody loves talking about their brightest baby! I love talking about ROS – our baby that's really come of age this year!

This baby, is now the doyen of our administrative burden reduction programme (and I know that may sound like a contradiction)

It's yet again another record year:

• Over 279,000 returns and 99,000 payments filed by the extended deadline of 15 November.
• an increase of 14% for both these over the previous year
• The value of payments made, €2,288 billion, increased by 3.9%.
• Over 74% of timely filers used ROS this year
• A record 37,000 returns filed on the last day
• The ROS Helpdesk handled 1,750 calls on that final day.

And it all happened this year without a blip!

We are well on the way to exceed the full year performance of 2.6 million returns or forms filed via ROS in 2006 and the €16.6 billion in payments made that year.

(Stop me if I'm becoming as boring about this as Steve Davis – at least I won't be singing to you!)

I know that we have put enormous effort into ROS – I know that you have also and I again express my thanks for your belief in this system and more importantly your increased usage.

The major recent ROS enhancements of course included the redeveloped Customs Automated Entry Processing (AEP) system on the 1^st of June. This has made life considerably easier for the internationally trading community in this country – they have taken with enthusiasm to it and about 99% of customs declarations of exports and imports are now online – probably one of the best take up rates in the world.

What else is new in ROS?

• ROS for employees, PAYE On-line was introduced in 2006
• Since earlier this year Employers can generate Tax Credit Certificates online
• You can now indicate if your clients wish to continue with paper P30s even though the P35 is filed via ROS
• From December, agents and customers will be able to supply offset instructions when filing overpaid VAT3s.
• Agent access to PAYE On-line will be available from January 2008.
• From Ist January the high-income individuals return (Form RR1) will be incorporated within the ROS Form 11
• The screens for the 2007 Form 11 are being modernised to facilitate Revenue and customers.

Slightly longer term we have three major developments to ROS:

• e-Registration
• e-Stamping and
• e-RCT

Work has commenced on these but they are major undertaking so I envisage 2009 as the year of delivery.

All of these ROS improvements, the new RTS service and the single point of contact for employers are just some recent examples of where Revenue examines processes and systems, listens to feedback, acts and implements mutually beneficial and cost effective changes.

Simplifying returns

One of the regular suggestions we get is to simplify tax return forms. It is topic that is firmly on our agenda. It is however also important to point out that some of the burden associated with these forms arises as a consequence of various tax incentive schemes and reliefs and the need to be able to cost such tax expenditures.

Real progress on simplifying returns is likely to be more practicable for on-line filers. This is part of the context for beginning a consultation process on a requirement that tax returns and payments for specific categories of taxpayers must be made electronically. A considerable number of fully computerised businesses still remain outside the ROS system and my aim is to bring them in. It will be done on a phased basis and it will be done in consultation starting next week.

I do appreciate that mandatory electronic filing and payment is not appropriate in all circumstances – it may for example be quite appropriate to make the claiming of high value reliefs conditional on e filing – it would however be inappropriate to make it mandatory for small business. Small business by the way needs simpler forms where that is possible – as a step in that direction I expect that the 2008 Form 11E (the shorter 12 page return) will issue (in early 2009) to a much larger number of customers who file paper returns.

Risk Evaluation, Analysis and Profiling (REAP) system

Sometimes, in talking about reducing the compliance burden, we concentrate quite a lot on forms and filing. We must of course also be mindful of the burden that audits and compliance interventions can impose – no doubt you are!

When we talk about REAP, our Risk Evaluation, Analysis and Profiling system, we certainly emphasise how this brings risky cases to the top for audit or intervention. But of course the other side of the coin is that it allows us to reduce our interventions with the less risky and most compliant customers. It does not reduce the number of audits we conduct, but it does focus them where they are most needed and it does enable us to move to a lighter touch with compliant businesses.

Consolidation and Modernisation of Legislation

The compliance burden can be aggravated by complex legislation and regulation. With this in mind we have engaged in a comprehensive programme to systematically consolidate and streamline older tax and customs legislation.

Examples include the Taxes Consolidation Act 1997, Stamp Duties Consolidation Act 1999, Capital Acquisitions Tax Consolidation Act 2003, VAT Regulations 2006 and consolidations in the excise area over a number of Finance Acts from 1999 to 2005.

The complexity involved in modernising legislation must not be under-estimated – we are working at the moment to consolidate customs legislation that dates back to 1876 – that was the year of Custer's last stand at Little Big Horn! And if some of you complain from time to time about the more recent powers given to Revenue have a look at that legislation – still extant and model of judicious “hang ‘em and flog ‘em” jurisprudence! I was assured recently by the way that most of those powers have not been used this century – given that this century is only 8 years old I presume they meant last century – but I was afraid to ask!

VAT on Property Review

Before I move away from legislation simplification I would point to the consultation process that was part of the recent VAT on property review – this is an excellent example of where the sharing of perspectives between Revenue, practitioners and business is mutually beneficial. Such consultation, with those on whom the changes will impact, does much to give early warning of problems and helps to ease the burden of implementation.

Recent Initiatives Aimed at Reducing Burden for SMEs

Let me speak for few minutes on developments in the area of easing the burden for SMEs. This is a priority for Government. The Minister for Enterprise, Trade and Employment has recently established a cross Department and Agency Group on Business Regulation. This Group will drive a programme of administrative burden reduction across five priority areas and will report to Government in July 2008. It will come as no surprise to you that taxation is one of these five areas! Revenue, along with some of the other Government bodies represented here today, is participating in this Group. Suggestions made by SME participants in our own consultative process and initiatives arising from the administrative burden reduction programme emerging from the Group will be part of Revenue's ongoing simplification agenda and burden reduction will be a significant feature of our next Statement of Strategy.

Direct consultation with a small number of SME customers also took place in 2006 with a view to developing a better understanding of the impact of Revenue regulations on this sector. Some key administrative burdens were identified during this process.

There is much we have already done:

• Approximately 70,000 businesses have benefited from the introduction of quarterly instead of monthly PAYE/PRSI filing arrangements.
• A similar number of customers can now file their VAT returns either bi-annually or three times a year depending on their circumstances.
• Increased VAT registration thresholds are estimated to take up to 8,000 businesses out of the VAT system.
• The VAT cash accounting threshold has also been increased from €635,000 to €1,000,000.
• In the area of corporation tax liabilities the threshold for the small company rule was increased from €50,000 to €150,000 – equivalent to profits of over €1 million. Over 97 per cent of Irish companies will benefit from this simpler and more straightforward system.
• Furthermore new or start-up companies with a tax liability of €150,000 or less for first accounting period will not be required to pay preliminary tax in respect of that first accounting period-instead they pay final CT liability at the same time as they are required to submit their tax returns (9 months after end of accounting period).
• We have also introduced a simplified procedure inrelation for the R&D tax credit of 20% of incremental expenditure.

Information and Understanding

I've spoken about burden reduction in terms of strategy, structures, systems, risk analysis, legislation and SMEs. Just a short few words about information and understanding.

Leaflets & Guides

We recognise that tax and customs legislation is not easy to understand. We therefore continuously review and update our website, forms, leaflets and guides – and our aim always is to simplify them. Our ‘Starting in Business Guide’ was published on our website in June 2007 and our ‘Employers Guide to PAYE’ was published on website last month – a copy of this guide on CD will have issued to all employers by the end of this month. Work on a comprehensive new Guide to PAYE for Employees, which we will distribute to all employees, will commence early next year.

PAYE Credits & Reliefs

Our simplification agenda also applies to our PAYE customers. The under-claiming of credits and reliefs by PAYE taxpayers has got a lot of airing recently. We have a clear four pronged strategy in this area:

• make sure everybody knows about their entitlements;
• encourage everybody to claim their entitlements simplify the way in which credits and allowances are granted
• use third party information to either give relief at source or automatically generate refunds.

It's a straightforward strategy, some of it already delivered and other elements coming on stream next year.

Direct Consultation with Customers

A key element of my role as a Regulator is to obtain views from all customer groups on how Revenue is conducting its business and delivering its services. Consequently we have started a series of direct consultations with customers involving surveys of SME and PAYE customers and the establishment of PAYE customer panels.

Both the response rates and the results of the surveys have been very encouraging. High response rates show that customers are keen to share their perspectives and the responses themselves are very encouraging for us.

The results of the SME survey for example indicate that almost 84% of respondents were satisfied with overall customer service delivery. On the PAYE side, 90% of respondents who submitted a form or called in person to a Revenue public office were satisfied with the service provided. Levels of satisfaction with the telephone, letter/fax and email services exceeded 80%.

The SME survey is on our website and we will publish the PAYE survey before the end of the year. The real value of these surveys is not in telling us we're doing well but in telling us how we can do better – I intend to repeat these surveys to measure trends over time.

Customer Panels

Finally on the subject of consultation, we have just set up PAYE Customer Panels-ordinary customers selected at random and regionally based. This is an opportunity for taxpayers to offer their opinions on Revenue services, communications, initiatives and developments. I look forward to direct feedback which will help us to respond to what our customers want.

Burden Reduction

It's a clichÉ then but there's no better way to sum up Revenue's response to burden reduction than a lot done, much underway and always more to do!

Let me move to the second part of this talk-working relationships between accountants, tax practitioners and Revenue including the latest state of play on OECD tax intermediaries study.

Background to OECD Tax Intermediaries Study

The OECD established the Forum on Tax Administration in July 2002 to promote dialogue and cooperation between national revenue bodies and to identify and develop good tax administration practices. The Forum membership is at Head of Tax Administration level – and generally the Heads of about 33–34 Tax Administrations attend.

At the FTA meeting in Seoul last year, the challenge to tax administration posed by globalisation and international non-compliance dominated the agenda. Everything from offshore accounts, trusts, shell companies, artificial shifting of profits abroad to the growing flows of capital into private equity funds was discussed. The discussions reflected very deep concerns on the part of some governments and their tax administrations about the capacity of firms to dramatically reduce their tax liabilities through complex international structures.

Following the Seoul discussions, the Heads of Tax Administrations committed themselves to continued cooperation through existing means (such as exchange of information) and to additional work in four areas. The most significant of the new work items was a study, into “the role of tax intermediaries in relation to non-compliance and the promotion of unacceptable tax minimization arrangements”, to be completed by the end of this year.

Tax Intermediaries Study

The findings of this study, which is being led by the UK, with the assistance of the OECD Secretariat, will be presented to the next meeting of the Forum of Tax Administration in Capetown in January 2008. Ireland is part of a ‘Core Group’ of countries assisting the UK/OECD Project Team with the preparation of the report. Our involvement in this Core Group contributed to the broadening of the initial terms of reference and focus of the study to reflect a more balanced view of the role of intermediaries and a fuller examination of their contribution to tax administration.

TALC

In contributing to the study we have emphasised that in Ireland, we have long recognised that tax intermediaries play a key role in the efficient functioning of the tax system and that we value the good working relationships we have with them.

At a CFE Conference in Brussels earlier this week I acknowledged this and (while emphasising that intermediaries in Ireland would be nervous if I gave them unstinting praise – although generally they deserve it) I went on to say that we have been very well served in Ireland by this dedicated and professional group which operates to high standards of ethics and professional regulation and whose role in promoting economic development and investment should never be underestimated.

The model of good working relationships between Revenue and tax professionals – epitomised for me by TALC – is by no means widespread among the international tax community – in fact it's a rarity as far as I can see. I hope that one outcome of the OECD study will be to allow the positive experience in Ireland to be fully understood and to influence my colleagues in other revenue administrations.

Where is the study at?

Final drafts of the study – now a draft report-are currently with all 34/35 Heads of Tax for their comments prior to consideration in Capetown. Assuming the Report is adopted it is likely that it will be published and that it will be accompanied by a Capetown Declaration.It's early days yet to be definitive about what the detailed conclusions will be but the emerging Report has somewhat changed direction.

It's noteworthy that Intermediaries are no longer the sole focus and that there is a much greater emphasis on the so called “tripartite relationship” between Revenue, Business and Intermediaries and on developing an “enhanced relationship” between these parties.It was particularly important to me that Report should recognise that national Revenue Authorities should have the flexibility to develop the enhanced relationship with intermediaries and business in a way that is compatible with their domestic circumstances, and particularly with their own capacity to deliver on their side of the bargain. I believe the Report will reflect this.

It is also important that it is recognised that, regardless of the quality of the tripartite relationship, that all Revenue Authorities accept that taxpayers do have the right to seek to vindicate their rights within the law and that Intermediaries have key role to play in this. This was not explicit in earlier versions.

Having benefited from an excellent culture of cooperation in Ireland between Revenue, Business and Intermediaries, we shared your reservations on the risk rating of intermediaries that was broached in the early papers of the Study. There is no simple approach to this. We are pleased to see that this recommendation does not form part of the present proposals.This is not to say that individual Revenue Administrations should not consider some form of risk weighting where clients of particular intermediaries consistently surface with aggressive avoidance schemes or with returns that do not fall within comparable sector or industry norms.

All in all then I am now more comfortable with the emerging thrust of this Report. I would like to express my appreciation to the ICAI and the other representative groups and some individuals who gave very useful input during the deliberative process. It would of course be the hope that recommendations in the Report would find favour with intermediaries and business as well as Revenue bodies — obviously this cannot happen until you see the conclusions.

Aggressive tax avoidance

The Report of course will contain a strong message about what it calls unacceptable tax minimisation (and which others may call aggressive tax avoidance or indeed aggressive tax planning).

I know you would all be disappointed today if I didn't say something on that subject! It's an area where, despite our generally good relationships, there is no great meeting of minds. There is certainly no agreed definition of what constitutes unacceptable tax minimisation/ aggressive avoidance/aggressive tax planning. So I'm not going to get into definitions. I just want to give you a few thoughts on fairness in the tax system.

Citizen confidence in the tax system in any country is essential. Such confidence comes from a belief that the system is fair, transparent and effectively administered – but mainly from a belief that the system is fair.

We all agree that tax evasion is unfair and offensive and we condemn it. Indeed I particularly congratulate your members on the responsible and effective contribution you have made towards reducing the levels of evasion in Ireland.

But I believe that the majority of people consider that aggressive avoidance is also unfair – furthermore I believe that that majority is growing.

Avoidance, no less than evasion, offends because of the real sense of inequity is generates and because it undermines the tax base and consequently the intentions of democratically elected Government whose programmes are predicated on expected Exchequer funding – almost all of which comes from projected tax revenues.

Defenders of avoidance put the case that tax is merely a matter of law. They argue that “if it's legal then it's ethical” and that other values or morality are irrelevant.Are they?

I believe that most people would find it hard to accept the proposition that just because something can be shown (or artificially structured) to fit within the strict letter of the law it then really doesn't matter if it clearly offends against the spirit and purpose of the law or against the intention of our Oireachtas.

I believe in fact that most people act by reference to principles or standards which are not defined in any Act of the Oireachtas but which are based on values derived from a sense of social and civic responsibility and from the “norms” of the community of which they are part. Their actions have regard to an unwritten code (call it an ethical or moral one if you wish) that is influenced by these wider principles at the expense of a principle of selfish personal gain or advantage.

Some here today may not subscribe to my views on this – fair enough. May I however make a point which takes a different tack to the moral/ethical argument. It's a more pragmatic – even a strategic one.

None of us, Revenue, Business, Tax Advisers operate in a vacuum. What we do has consequences, or to put it another way every action can provoke a reaction. There is always a tipping point.

Governments, who may judge that their capacity to deliver on carefully designed programmes is being undermined by artificial depression of their expected tax revenues, or a Revenue Administration which sees its carefully constructed legislation creatively sabotaged will, to put it bluntly, hit back. So even if you don't buy the ethical/moral argument what about the strategic one – the one where perhaps pragmatism or, dare I say it, even enlightened self-interest kicks in?

In Revenue we are significantly ratcheting up our anti avoidance activity. As of today we are actively challenging 46 avoidance schemes – 26 of these relate to Direct Taxes and 20 to Indirect Taxes. About half of the schemes are at various stages in the appeal process – 7 have reached the Higher Courts.

You may take it that this area will be one of our key priorities in the coming years and that the numbers of challenges will increase. We will match aggressive avoidance with aggressive anti avoidance interventions.

I'll leave tax avoidance at that – I'm just sharing a perspective!

Developments at EU level including CCCTB proposals

My final area in this talk today relates to developments at EU level including the CCCTB proposal.

Let me talk first about VAT.

VAT

At EU level the simplification/improvement in the VAT area is being carried out in line with the EU Commission's ongoing modernisation agenda. I could spend a lot of time talking about this but I will just say that legal certainty and compliance burden reduction is Revenue's consistent approach to the emerging proposals.

The Package of EU measures to modernise the VAT system include:

• Change the place of taxation for Business to Business (B2B) and certain Business to Consumer (B2C) cross-frontier supplies of services. This will better reflect the consumption nature of the tax.
• In conjunction with the above, expand the reverse charge provision for cross-frontier B2B supplies which simplifies the system and has cash-flow advantages for taxpayers.
• Establish a one-stop-shop for taxpayers who have liabilities in more than one Member State in respect of their cross-frontier supplies of services. This will eliminate the requirement for taxpayers to register and file in more than one Member State, which will considerably reduce the cost of compliance.
• Streamline the procedures for claiming cross-frontier VAT refunds, including speeding up the timeframe for payments to taxpayers.

EU measures to tackle VAT fraud:

• In the negotiation of EU measures to fight VAT fraud, we are seeking to ensure a balance is struck which effectively tackles the fraud but does not impose an unacceptable burden on the compliant taxpayer.

EU review of VAT exemptions for financial services:

• We are working towards the improvement of the EU financial services sector in terms of competitiveness on international markets and introducing legal certainty for taxpayers especially in relation to the application of ongoing ECJ case-law in this area.

Code of Conduct

The EU Council Code of Conduct Group is continuing its work of monitoring, on a “soft law” basis, national tax arrangements that may, potentially, be harmful. As you may be aware, the principal work of this Group is concerned with

• monitoring the “roll-back” of national measures that have already been found to be harmful by the Group and
• reviewing new national measures, that may, potentially, be harmful, to determine whether the Group considers them to be actually harmful and therefore contrary to the political agreement represented by the Code of Conduct.

The UK Financial Secretary, Jane Kennedy, has recently succeeded Dawn Primarolo as Chairperson of the Group. Coinciding with this change a review of the procedures of the Group is being undertaken. This review is addressing among other areas the general guiding principles concerning evaluation of measures.

The review has been prompted by the adjustment of the Group to an enlarged membership and by the fact that as tax systems and proposals evolve, so views as to how the Code of Conduct Group should address them are also evolving within Member States.

Common Consolidated Corporate Tax Base Proposals

Finally then to the proposal of the European Commission to introduce a common consolidated corporate tax base (or CCCTB) in the EU.

It's attracted a lot of attention and debate in recent months.

Essentially the CCCTB would – theoretically at least -provide a harmonised set of rules for companies to calculate their taxable income, it would then be consolidated on a cross Europe basis and the consolidated taxable income would be allocated between the Member States where it would be subject to tax at the rate applying in that Member State.

The details of the CCCTB proposal remain under discussion in a Commission technical working group. A formal Commission proposal is expected sometime in 2008. Ireland is taking part in the working group with the other member states – but on a strictly without prejudice basis. Many technical issues remain to be resolved.

It is not for me to comment on the political dimensions of this proposition, and I should make it clear that there is as yet no proposal and the Commission has not completed its impact assessments to determine whether it will want to proceed to that stage. However it is valid for me to refer to some practical aspects based on the technical work I referred to.

• The Commission suggests that one reason for having a common consolidated corporate tax base is that it would reduce the costs of tax compliance for groups of companies that operate across borders within the EU. The extent to which the proposed system might do this is far from certain. A major part of the rationale for its introduction is the removal of compliance burden in relation to cross border transfer pricing. It is clear from work done to date in the Working Group that significant transfer pricing compliance issues will remain, both for transactions with companies within the CCCTB area and those outside of it.
• The Commission's suggestion is that the CCCTB would be optional for groups of companies and this is seen as an essential element of the scheme from a business point of view. However, some Member States question optionality and consider that it should be mandatory. Any introduction of the CCCTB on an optional basis means it would run side by side with the national system. This would impose a considerable strain – requiring both tax officials and tax advisers to be expert on both systems and to run both in parallel.
• The Commission has apparently abandoned the idea of piggybacking on International Accounting Standards (IAS)/ International Financial Reporting Standards (IFRS): the start point would probably still have to be the accounting profit prepared under 27 different sets of national GAAPs (Generally Accepted Accounting Practice), which makes the sense of what is proposed even more difficult to comprehend. And comprehensive rules will have to provide for the conversion of each accounting profit into a consistent CCCTB profit figure across the CCCTB area.
• Nor is it at all clear at this stage how the proposed system would be administered. Many basic questions have yet to be answered:
• Would Revenue personnel from one Member State have a role in administering a tax system for companies in another Member State?
• How would tax returns be audited?
• What mechanism would be available to groups of companies to appeal against assessments that they consider to be incorrect?
• Where would those appeals be heard?
• Are there potential legal difficulties on the jurisdiction of the Courts of one Member State handling such matters in relation to a company that operates in another Member State?
• How could changes in the rules to adapt to new market conditions or to correct the inevitable unintended impacts be managed with any level of flexibility? – this audience, more than most, will fully understand how agile the Irish tax system is in responding to such needs.

Formulary Apportionment

The mechanism for allocating the consolidated tax base to the member states is a key element of the proposal. The Commission has suggested that this should be done by way of a formula apportionment. The details of the apportionment formula have yet to be worked out. However, the suggestion from the Commission at this stage is that it would be based on factors such as payroll, physical assets and sales – possibly by destination. Any such method has to be arbitrary: the separate entity/arm's length pricing principle – currently the only internationally accepted fair method of profit allocation – would be abandoned. Most Member States are concerned at the potential effect of this on their tax revenues and are struggling for ways to estimate the impact. Our own economy is increasingly dependent on traded services and intellectual property, which do not fit easily into the more traditional – almost “old economy” – formulae suggested. Apportionment factors involving, for example, physical assets only, or sales by destination only, would favour the larger core countries.

But the wider and more important tax competition element here – which is lost sight of in this very technical and inward-looking proposal – is competition with non-EU locations.

There is little hard evidence of how the proposed CCCTB would reduce compliance costs as suggested by the Commission. There are enough practical questions and concerns to suggest that this is simplistic assertion. There is a growing questioning of the realism of this proposal. There is a need for all concerned – and especially business and tax advisers – to make sure they understand the practical implications of what is being proposed.

It's hard to escape a conclusion that the considerable resources that are engaged in promoting this fiscal adventure would be better engaged focussing at targeted measures to address clearly identifiable problems that will yield greater benefits for all member states.

Conclusion

Ladies and gentlemen I trust I have given you a good overview of topical developments in the tax system from a Revenue perspective.

In all the areas I have covered, engagement with agents and practitioners is critical to informed thinking and future developments

Thank you.