 While Apple's CAIA had an ETR of 0%, some have an ETR of 2.5%.In June 2009, the Irish State established the "Commission on Taxation", to review Ireland's tax regime, and included Feargal O'Rourke, the "grand architect" of the Double Irish tool.In September 2009, the Commission recommended that the Irish State provide capital allowances for the acquisition of intangible assets, creating the CAIA BEPS tool.