 I'm going to talk to you today a bit about Irish corporation tax policy, and I intend to cover three things. One is where did Irish corporation tax policy come from, where is it at today, and how has it perceived by business, and has it perceived internationally, and then where might it be going, and what are the challenges in the future. I suppose to start off with where did it come from, well I guess you have to go back to the late 1950s, as most of you know, which is when the current Irish corporation tax regime was really set. What was the context at that time? In the late 1950s Ireland would have been one of the poorest countries in Europe. I think Sean McBride used to say that the Irish economy or the Irish country was the only country in Europe that had been systematically colonised, in the sense that you'd had almost genocide of the population at times, you'd have mass appropriation of the wealth of the native population, etc. And you had a deliberate policy by the colonial power to ensure that Ireland was not allowed to develop an industrial base, that was a deliberate policy directly leading to the famine. And I suppose you might say it's a bit longer to be talking about the famine, but I mean just put that in context, in 1957 when we commenced our current corporation tax policy, my grandfather would have been alive, and he was born in 1880 and in his childhood he would have spoken to unknown survivors of the famine, so that generation was only one degree of separation away from the famine, and the population decline that set in during the famine was still continuing in the late 1950s, we'd had a population decline since the famine right through until the early 60s, and Ireland had a population of I think between eight and ten million, depending on who you believe in the 1840s, Britain had a population of 19 million, by the time you got to the late 50s the population of this state was 2.8 million or 4 million on the island and the British population was 50 million, and as we know there are six and a half million people on this island, but almost 50 million people who claim to be Irish Americans, so the despoilation and the depopulation in the country had been massive and quite unprecedented in European terms. You also had a country that had a disadvantage in being a peripheral location, I mean we're geographically in the same position compared to Europe as the Ireland Islands are to Ireland. That's not a small disadvantage. I think as with Commissioner Fihili, I have the honour of having been born in the great city of Limerick, but we're both working in Dublin, and we know that large centres tend to attract investment, they attract people, they attract wealth, it's almost inexorable, and I think peripheral locations have a distinct disadvantage. We're also a country that doesn't have a lot of natural resources. Natural resources within the EU are generally not shared, we don't share German steel or coal or we don't share Norwegian oil. In fact I think the only thing that is shared are fishing grounds, most of which are Irish, they seem to be the only natural resource that's shared within the EU. So Ireland started in the late 50s from a position of quite a lot of disadvantage, and I think when we talk about fairness and taxation policy and so on, that's important to remember, and I think that Irish corporation tax policy was designed to redress some of the natural disadvantages that the country suffered from, and I think in that regard it's been very successful. I think throughout that period it's important to point out that unlike many other countries, the Irish corporation tax regime has been very, very transparent, it's been very open, it's not based on secret rulings, it's not based on special deals. If you want to know what the deal for taxation is in Ireland, you just open the tax legislation and that will tell you what it is. There have been a number of studies carried out, the Department of Finance did one, we did one at KPMG, and I see PWC did one recently, all of which confirmed that the effect of rate of corporation tax in Ireland is very similar to the nominal rate of 12.5%, and again that's not the case in every other country. So I think we've operated in an open and transparent way, we've developed a system which is attractive to business, we've complied with the EU law, and the system has been pretty successful, and that population that bottomed out at 2.8 million in around 1962 or 63 is at around 4.6 million I think now, 4.7 million, and I don't think it's a coincidence by the way that the economy and the population started to recover at a time when we started to be sensible about having a taxation regime that was attractive to business and attractive to bring investment into the country. I think Irish policy makers have been clever throughout that period, we started off as you know with export sales relief, when EU law meant that we had to change that, we brought in manufacturing relief, and when EU law meant to change that we moved to having a general low rate of corporation tax which was a very significant decision at the time, there would have been a lot of concerns about extending a low rate of corporation tax to things like supermarkets and domestic banks and so on, but a brave decision was taken and I think the country benefited. I think policy makers have done an excellent job throughout the recession in protecting that 12.5% tax rate because I think at various times including during the bailout and so on, that tax rate would have been under pressure and I think Irish policy makers can be proud of the fact that they've managed to retain that low rate of corporation tax in the face of quite a degree of pressure over the years and it's something which has I think enhanced Ireland's reputation internationally that despite the pressure that the country was under, we managed to retain a regime that was attractive to business. In recent years, one of the threats that we would have identified maybe three or four years ago to Ireland's position would have been the increase in competitiveness of the UK in particular and we saw the UK for example introduced a patent box regime at a 10% rate of corporation tax and a number of other measures in the UK and it's interesting to see that I think in the budget this year I think Ireland responded very well to that. The announcement of the knowledge box which I think we can anticipate will be competitive with the UK regime is very, very welcome. I think it should mean that Ireland will remain ahead of the UK in terms of its corporation tax offering. That's important because the UK is a fairly obvious alternative choice to Ireland. We speak the same language as geographically close and so on. The move to remove the base here for R&D tax credits was also very important because again that redressed a potential competitive disadvantage for the UK and some of the moves on the SARP, that's the special tax relief for assignees coming to Ireland in particular the removal of the cap on the relief is again very important because it gave us a position where we could undercut the UK competitively. If you add together those three measures combined it's really very positive in terms of inward investment for the country. KPMG UK do a survey of business asks them what country do they think is the most attractive for inward investment every year and I think last year Ireland was sixth and the UK was first and the survey results are just out this week and those positions have been more or less reversed so Ireland is now in that survey back to the number one position which is great to see. In terms of challenges going forward I just mentioned maybe three or four things. One is the obviously it's interesting news in the press this morning if it's true and I presume it is that there may be a 12.5% corporation tax rate or perhaps even lower across the border in Northern Ireland in the near future. That will be an interesting challenge. You'll have a strong competitor for business with the south of Ireland going forward. I think the BEPS project most of the BEPS project I don't believe is a danger to Ireland. There's a lot of stuff in it which actually could be good for Ireland because a lot of the project is designed to align the allocation of profits with where there is substance and inward investment in Ireland tends to have substance and I don't think as a country we're particularly interested in attracting inward investment that doesn't have substance so that could be good for Ireland. One feature of it is that it's likely to align the allocation of profits globally with where key decision makers are made and that will mean it will be important to ensure that we continue to have a tax regime that makes it attractive for key decision makers to locate in Ireland and that's one area where we would say in the future for the work might have to be done. I think the area within BEPS that is the biggest threat to Ireland is the area the proposals on tax treaties. The proposals that's currently framed in our view are pretty dangerous to small countries in fact I'd go so far as to say I think they're quite discriminatory against small countries that may not be deliberate and certainly we will be making submissions to the OECD and so on the detail of that I won't bore you with the detail here or I'd be here for a very long time and the final thing I'd say in terms of our policy going forward we have done a very good job over many decades for foreign direct investment. I think that our tax regime that's available to domestic entrepreneurs isn't as competitive as it might be particularly when you compare to our nearest neighbour and particularly the 10% rate of capital gains tax entrepreneurs from the UK is very attractive. You will now potentially have across the border in Northern Ireland a 12 and a half percent rate of corporate tax combined with a 10% rate of capital gains tax so 33% our rate of capital gains tax I think is pretty uncompetitive with that. But overall the message I'd leave you with this that I think Ireland has evolved and developed a tax regime for business that it's fair it's transparent it's competitive and it's now according to our latest survey the most attractive in the world for immigrant investment. Thank you.