 I have to say that unfortunately one of the most powerful organizations, law firms and consulting firms are of course helping multinationals to avoid taxes and we know that the border line to evasion of taxes is sort of blurred and they're participating in that and I think just because it's basically a white collar business should not stop us from thinking about those in corruption terms as well. Welcome to Davos and this special debate from the World Economic Forum on France 24. We're here today talking about a problem which sees governments lose hundreds of billions of dollars in tax revenues every year. The rules around taxing multinational companies are almost 100 years old and the rise of digital giants has made it more difficult for countries to get their fair share in taxation. So can a new global agreement be found on tax without starting a trade war? To discuss this I'm joined here today by Catherine Episto, the Professor of Comparative Law at the Columbia Law School in New York from France, the French Finance and Economy Minister Bruno Le Maire, the Secretary General of the Organization for Economic Cooperation and Development, Angel Guria and from Transparency International, Delia Ferreira-Rubio as well. Thank you all very much for joining us. Angel Guria I'd like to start with you. Your organization has put forward a plan, a new plan to tax this area to tackle this difficult issue. It has two parts, one will change the taxation for digital firms, the other aiming to set a minimum corporate tax rate for companies around the world. This is not a new problem. It's been needed to be tackled for quite a while. What makes you think that this plan can succeed now where we haven't found a solution before? This is a plan where 137 countries are involved, which means that the ownership and the source of the ideas and the source of the initiatives are from the countries themselves is not just that the OECD is putting forth a proposal to be discussed. And the other question is that although the issue has been on the table for quite a while, the world has not organized itself around a few of the concepts that are fundamental here in order to address them. And last but not least, the question of digitalization of the world economy is happening more and more and more every day. This is not about digital companies, please let's be clear. This is not about the countries of the companies of any one particular country. This is about the process of digitalization, where if you're a finance minister you see the base shrinking because digital is all over the place and happening more and more and more. And the question is how do you address a new set of rules? How do you establish new rules of the game to deal with this new reality where before one of the key rules was for example that you have to have a physical presence in a market. Right now you can be anywhere in the world and doing billions and billions of business in a particular location, a particular country, in a particular city and you never even stand in there or stop by. Now these are the kinds of things we use to have things like transfer payments and arms things, principles and things like that would apply to what I would call the more traditional type of economy. The new economy, the digital economy requires therefore that we establish new rules in order to avoid what you very aptly described hundreds of billions of dollars being either not paid or divested or simply ignored and I would say legally in a way because effectively the companies are simply seeking to see where they have the lowest taxation jurisdiction. So we just have to, this is, you know, there's so exciting about digital, so exciting about technology, et cetera, but this is one of the consequences that we have to face in order to update and upgrade our international taxation system. Okay, and Delia for Erubio, as Angel Guria says, this is legal, these companies are using laws that exist to arrange their tax affairs. Is this then a corruption issue for you given that Transparency International is an anti-corruption organisation? Well, we are working on that because we think that it is related with corruption. In some cases it's legal, in other cases it's really and clearly an avoidance of tax paying and it in many cases has to do with shell companies or offshore jurisdictions. But we think is that in this digital economy we have to reassign the taxing rights. This is the question, who is entitled to put the taxes or to receive the taxes revenues. The country where the companies are located or the companies, the countries where the users and the consumers are using the services and creating the value. And of course, this is not just taxation, this is a global issue. It has to do with sustainability, it has to do with good governance, it has to do also with fairness in the global economy. And of course, transparency is the key principle on that. So we are working hard in this realm because it's connected with all the other topics that Transparency International is already working on. Catrin, first I'm going to come to you next on this because there's an issue too about how companies are structured that allow them to be able to do this. Is tackling the tax issue the most pressing way to address sort of a broader how we treat companies? It's certainly a very important one because many companies organize themselves around tax issues and unfortunately, ideally they should not be doing this, they should be doing this around business rather than taxes, but it's a very common thing and I just want to come back to the question of corruption. What is legal and what is illegal is of course a fine line, it's a very blurred line and because no tax code can ever be watertight, so we're interpreting and we're trying to find ways around. And I have to say that unfortunately one of the most powerful organizations, law firms and consulting firms are of course helping multinationals to avoid taxes and we know that the borderline to evasion of taxes is sort of blurred and they're participating in that. And I think just because it's basically a white collar business should not stop us from thinking about those in corruption terms as well. Bruno LeMair, your government put in place attacks on digital companies, revenues of large digital companies last year, you've now suspended payments of those tax under pressure from the United States, will those companies ever actually pay this tax? The digital companies in France will pay their due taxes in 2020 and they want to be very clear on that. We were the first country to introduce a digital taxation in 2019 for one single reason very well explained before, which is that there is a loophole in the international taxation system. The loophole is digital activities. The biggest companies of the world are making huge profits with millions of consumers in territories where they do not pay their due taxes. Nobody can accept that and we will never give up. Let's be clear. We have decided to introduce a fair digital taxation at the national level. It has been paid in 2019. We have just given some time to have an international solution at the OECD on the basis of the excellent work done by the OECD because I think that we are all the view that it is far more preferable to have one single international solution for a fair and efficient taxation of digital activities. We are still having many national taxations all over the world, especially in Europe. That's our point, but let's be clear, in 2020 all the digital companies that are under the scope of either the OECD or national taxation will have to pay. But we want to give its chance to this international solution. So we have found an agreement with Stephen Minuchin. We have seen the process of defining the basis at the OECD. I think that it is far better for all of us to have an international negotiation at the OECD with the view of finding a compromise and an agreement by the end of 2020 instead of entering into a trade war between the United States and Europe because a trade war would have two consequences. First a slowdown in growth and then it would mean the end of the international negotiation. The end of an international solution for both digital taxation and minimum taxation. So I really think that we have all to give its chance to this international negotiation. We are united in Europe and I hope that by the end of 2020 we will get this new international taxation system. I agree, this puts a lot of pressure on you and your organisation to get everyone on board for this. We know that the United States have issues with the OECD plan. Are you optimistic that those issues can be resolved? Indeed. We are on track. This is something that people have to know. This is not something that started yesterday and this is certainly not because of this flare up that there was at some time. I read yesterday in one of the newspapers that there was also a conversation with the UK and the United States and we know that there have been exchanges with Italy, with Spain, with Turkey, why? Because there are more than 40 countries today that are participating in this international effort to put a deal together that are ready to go out on their own as Bruno Le Maire just suggested if there isn't an international solution. And therefore what you will have is not only a diversity, you will have a real cacophony of different ways of interpreting and different ways of realising how it is that the companies should be paying their taxes, how much pain the societies feel that they have to inflict or dart or who wants to be more promotional, who wants to be attractive there so you will have this competition about this. This is not desirable and everybody is trying to avoid it. I have to say there is a common, this expression that you have heard from the French Minister of Finance is shared widely by the 137, but the question is of course there are 137 voices, 137 opinions. So now are we on track? Yes, we've been working on this particular issue of digital for more than two to three years now. We are on track next week. Actually there will be a discussion at the OECD where all the elements are going to be put in place. The idea is that by June or July we will have all the numbers that are required and that in the second half of 2020 we go for implementation. Now is this going to be an issue or something? Do you need the United States to be on board for that to work? We need everybody to be on board, 137 to be on board, but what is really very important for the audience to know is that they have all been able to shelf or put aside their differences for the benefit of a common solution. These two pillar solutions that you mentioned at the beginning, etc, all is shared and it was the result of the work of 137 countries. Delia, when you hear an international plan sounds great, sounds like everyone will, you know, it could solve a very complicated problem. Do you have faith that these agreements, even if it is reached, is going to be applied in a way that is as transparent as your organization would like? Well, one problem is implementation because we are talking about the rules. And I agree completely, the rules should be global. We have a global problem here at the Manifesto 2020 of the World Economy Forum. It's a stress in stakeholder capitalism, which means collective action. We cannot solve this country by country because it will create, among all other problems, double taxation, for instance, so this tax competition to go into the lower part of the scale. So we need this comprehensive solution. But once we have the rules, the rules should be implemented. And there we have another problem. So the rules should be absolutely clear. The work the OECD has done till now and you have been very open in order to allow participation openly for many stakeholders. And that's very good. The work done till now offers clear principles and, I suppose, clear rules in order to be properly implemented. But then it will be at the task of each of the agencies in the countries to really put this with transparency at the very first principle. Because we need to know where companies are providing their services. Where are the consumers? Where is the creation of value? And once we know that, we want to know who is paying taxes and how many taxes they are paying. That's transparency for us. Katarina, is that in the legal structures available to companies? Is that going to be something you think is going to be enforceable? Well, I think this is the big question is whether these tax rules will be enforceable. It's a question not only of the capacity of tax authorities in the different countries, but also of the willingness of the companies to share their information with the rest. Because we have to know where they have raised basically the value that we're trying to tax. And I think there can be a lot of disputes. And I realize that, of course, they have lots of thoughts about an arbitration tribunal to resolve these disputes. I would like to know more about that. I would like to know who is sitting on this arbitration tribunal who can appoint the arbiters and how this will be enforced. And one thought I just have, which is a skeptical thought, is sort of the amount of disputes that could be about what is a residual tax profit that shall be taxed, what is the right threshold, all kinds of issues that will be raised. The companies have a lot of resources. They can bring a lot of disputes to arbitration. And the question is how many countries will have the time and resources to go through these kinds of disputes to make sure that they can really collect their tax base. So I'm sort of nervous about the implementation phase, with all due respect to what has been achieved. Anglore, do you share that concern? Arbitration is a big one, you know. As Katerina was saying, companies come to huge resources to challenge re-tax railings. Listen, Stephen, implementation, implementation, implementation. Of course, this is the, the I word is crucial. However, what you have thought that in 2019, actually, that's last year already, 50 million bank accounts have been revealed. And they are all in the desks of the tax men and women of the different authorities in the world. And that they are worth the 50 million bank accounts. They are worth 5 trillion euros, which is about a third of the US economy. And they're already about 102 billion, billion euros of back taxes and, you know, fines and things that have been paid by the people who have gotten to the conclusion that there's nowhere to hide, that you just have to pay the taxes because your name is already on the tax man or tax woman's desk. And they're going to call you and buy you a cup of tea. And they're going to say, well, you know, we got to, there's an inconsistency here. OK, so that would have been just unheard of. Two, three, four years ago. It's happening as we speak. The same thing. And you believe the same thing can apply to companies. Absolutely. The companies now, we have 14 pillars out of the 15 have already been enacted. And they're moving forward. There's about 250 billion per year that the companies are not paying. So we're going to see how we make inroads into that. The rules for that have already been in place. What is missing, the digital taxation? Because of the complexities, because it's moving so fast all the time, and because you needed the consensus. Now, what happened in the meantime? You know, what happened in the meantime was we had a very big tax reform in the US. And therefore, that allowed for the consensus to join everybody else in the world that have been for years trying to get a deal like this. So yes, we believe it's possible. We believe that the conditions are right today to be able to succeed. OK, we're going to take a short break at that point. Join us after these headlines on France 24 for more from the World Economic Forum in Davos. I hope you're all enjoying the news headlines. We won't get to see. Yes, Mark, tell me. OK, I hope you all enjoyed that. Welcome back to the France 24 debate from the World Economic Forum in Davos. We're discussing the challenge of how to tax digital companies. Bruno Le Maire, we're talking about a new rule book in this area. Your country went first with the 3% levy on digital revenues for large companies in this area. The experience you've had, the response from the United States, is this a cautionary tale for any country that wants to go ahead without there being an international framework? I think, once again, that it would be far better to have an international framework for everybody. Otherwise, once again, you will have the UK, Italy, Spain, Austria, many countries introducing their own national taxation. I just want to recall how unsatisfying the current situation is. To be very simple, the biggest you are, the less taxes you pay, that's the current situation. Nobody can be satisfied with that. Just because you are digital companies, you do not have any physical prisons, so you don't pay any taxes. You have 50, 60, 65 consumers in France, but you do not have any physical prisons, so you don't pay any tax or a very limited amount of taxation. That's not acceptable. So we have introduced our own taxation system, and I think it's interesting to enter into some details. The French system is a very simple one, but I fully recognize that from an economic point of view, that's not the best one. It's simple, but from an economic point of view, we can do better. All national taxation is based on the turnover. If you have a turnover above 750 million euros, you have to pay our national taxation at a level of 3%. But having a taxation on turnover cannot be satisfying from an economic point of view. So we have to build something different, and that's exactly what we want to do during the year 2020 on the basis of the extremely good job made by the OECD, by Henri-Ele Gouria, and by Pascal Santama. The work that has been done on the OECD-11 is based on the level of profits. And of course it's better to tax profits rather to tax the turnover. Then you have to define the parameters of the taxation. The basis would be the profits. If you make over-profits, super-profits, you need to be taxed. You have to define the level of super-profits. Is it 10%, is it 15%, is it 20%. We can have a very long debate about that and it will be up to the negotiation to define this level. Then on the parameters, you need to introduce some parameters to know exactly how you are doing business in one country and how you are doing profits in one country. You can take, for example, the number of consumers. It might be one very interesting parameter. You can take the level of your expenses for advertising or marketing. It can be a second parameter. And then you have to define the threshold 10 over 10, for instance, on the basis of the profit you are making. And the very last point of this global framework we are working on is tax certainty. That's a key point for many countries to be sure that this is something fair and solid. We are in favor of introducing, for instance, kind of arbitrage system, arbitrage body, so that the private companies could be sure that there is tax certainty and there won't be changes all over the world every six months or every year. I just want, through this presentation of the OECD solution, to insist on the fact that everything is on the table. We just have to decide. If we want to avoid either a loophole in the international taxation system or many national solutions that could be detrimental for all of us, we have everything on the table. Just decide. Just give the impetus. So was this part of your government's strategy by going ahead of this tax before there was a plan? Of course. You must have expected that the US were going to... Our strategy is quite clear. We want everybody to be aware that there is a problem. Everybody must be aware that we can't go any longer with the taxation system in which the richest companies, those who are making the most important profits, are paying less taxes. So I'm very happy to see that today in Davos, that's one of the key issues. And I think that France has been successful in putting this question of fairness in the international taxation system at the core of the international debate. That's the success of France and that's the success of President Macron. And surely bringing the United States to the OECD table, as it were, is also the goal of having the dispute that France has had with the United States? They've been on the table all the time. They've been at the table. With reservations. Not all the table, but at the table. And they've been participating rather actively. But there is something that you have to understand, which is really at the root of what Bruno Le Maire just mentioned. The man on the street, when you're talking about the transparency question, the man on the street, the middle class is captive. In fact, their taxes are taken away even before they get the paycheck. And they suddenly find out that the richest men and women in the world pay very little taxes and they have them nested out in some strange place in the world. And the same for companies. The small and medium-sized companies, they are in a way captive. They're captive within their borders. They have to pay 25, 28, 30, 35 percent, whatever the tax is. And now they find out that the biggest companies in the world pay 0.02 percent, which is a very nice low rate of taxes you will realize. As we have found from all these investigations by the EU from some of the largest digital companies, et cetera, so basically there's a very deeply rooted political issue here. It has to do with the question of trust, which is one of the biggest casualties of the crisis that we have had here. There was a casualty of growth, there was a casualty of jobs, but there was a casualty of inequalities, but there was a great casualty of trust. And if people feel that I have to pay and the big guys don't have to pay and the small companies have to pay and the big guys don't have to pay, obviously that produces the people, you know, eventually going out in the street and protesting and saying, I don't like what I have today. Daley, is there a risk that this is a group of rich nations getting together, coming up with a plan that is going to leave developing countries unable to compete in different ways as they would to compete on tax, for example? But if you have 130 countries, you have developed and underdeveloped and more coming. But that's the point. We are not here talking just of the consumers and users of France, UK or the big countries, the developed countries, the rich countries, whatever the name you can add. We are talking about underdeveloped countries where users are located, all are connected, fortunately, using this digital economy. And in this world, it's not only tax section the problem, we have a political problem here, a governance problem. And in the civilian capitalism, we citizens and our data has been transformed in raw material for these big companies which are using our data freely to create algorithms and artificial intelligence and machine learning and all that. And in our countries, we are not receiving the taxes that should be used in order to solve the problems in underdeveloped countries. So for instance, if we talk about sustainability, other concept that is very highlighted in the manifesto 2020, the SDGs, the Sustainable Development Goals, said we have to solve the problem of water sanitation, poverty, climate change, et cetera. And how are countries going to do that if they don't get the taxes that has to do with the activities performed in their countries, not physically present, but really has to do with users and consumers in countries creating value. So this is something that has to do with fairness of the global governance. And I would really be very happy that the result of this is not that finally consumers and users are paying the taxes for the big companies because in some countries that is what is going to happen or is already happening in some underdeveloped countries. Catarina, there's a conversation happening in the United States about regulating big tech when it's happening in many parts of the world, very seriously in the United States, but regulating big tech is taxed the way to attack that? I think it's one of them. And I think that what I would like to add to the conversation here is I think we can think about the big tech companies actually taxing consumers. So in some ways, consumers are double taxed, right? Because the big companies are basically harvesting the data or the raw information that we all produce for free and then are using them and monetizing them and making the money off that. And then are not paying taxes to the countries where these very consumers live, including actually in the United States where many of the big tech companies reside because they get a big tax break there as well. So I think one way to get them under control to some extent I think is to impose taxes wherever they are and wherever they are active. Okay. Brunelomer, you've delayed your current process to the end of 2020. What happens at the end of 2020 if there's no global agreement? Are those companies gonna get a big bail? In that case, we will come back to the national solution. And the digital companies will be taxed under the French national law because we have just decided to postpone the prepayment of April to December to give some time for the negotiation. But in any case, digital companies will have to pay. I would really prefer to have a taxation under the international law. And if we are successful, it will be under the international law. But if we fail, we will come back to the national solution. And I fully share what has just been said about the fact that when you are making profits in one country, either a developed one or a developing one, you should pay your due taxes in that country. So there is a problem of digital taxation, but there is also a very important issue which is minimum taxation. And on that very specific point, we are exactly on the same line with the US. And that's also a political issue because when you are a single citizen earning, let's say 2000 euros per month with you and your family, you have to pay your due taxes in France and you have no possibility to put your earnings abroad in a paradis fiscal. You do not have the choice. You must pay your due taxes. And I don't know why our citizen would be obliged to pay their due taxes in our territory and the companies could withdraw their profits, put them in another country to pay less taxes. And the response to that problem, which is tax evasion, is minimum taxation. And on that very specific point, which is the second pillar of this re-foundation of the international taxation system, I really think that we are close to an agreement and it would be a total game changer if we can prove to the citizen that everybody will have to pay a minimum level of taxation and that this would be the end of tax evasion. And in your discussions with your American counterpart that we know you've been having plenty of this week, do you share that opinion? Yes, I think on that very specific point we are exactly on the same line and that's why I'm hopeful that we can find a global agreement at the end of 2020 because the US are very much interested in introducing a minimum taxation at the international level because they suffer also from tax evasion and I've always made clear that this is a package. If you want minimum taxation, we also need digital taxation. Just to be very clear on minimum taxation, we propose, the French government propose, a level of 12.5%. Today, you have very important companies making huge profits in France, withdrawing their profits from France and paying a level of corporate tax between two and 4%. I don't want to quote the country but everybody knows which country I'm thinking of. If we have a level of minimum taxation of 12.5%, it means that France could have 10 points of revenues of taxation coming back to the public goods in France and to the French consumers. Conveniently that 12.5% is also the minimum the lowest corporate tax rate in the European Union which is in Ireland and is that part of, you know, coming up with that figure? I don't want to mention any European country because by the way, I'm a friend of all the member states of the EU but frankly speaking, I will be very frank with you. A race to the bottom is not the future I want for Europe. And Ireland has signed up to participate in this process and supports the OECD efforts in this area? Ireland is very enthusiastically working here because what is at stake, and by the way, 12.5% is not the lowest in the European Union. There are at least a couple of others which are below. So, 12.5% is because it's a little higher than 0.02. But most importantly because it establishes a level playing field. This is why this is so important. The idea of a minimum tax and they say, well, I mean the corporate taxation is normally 25 or 28. So 12.5 is like a giveaway. Oh well, opposed to zero or opposed to one or 2% or the two to 4% that Bruno was mentioning, then obviously 12.5% would seem to be a come of a buffer, a minimum in protection. But it gives certainty also. Why would companies go for 12.5% when today they are paying one or two or 4% because the one day if they're caught by, you know, Margaret Feisigar or whatever they're called in and they say, you owe me 14 billion, you know, from one day to the next. That type of the incident would no longer be possible. In fact, it's no longer possible today, I have to say, because all the double Irish and the double Dutch and the double this and the double that all have been dismantled in the process of transparency, but it creates certainty. And this is something which Minister Le Mer alluded to a moment ago. Companies are planning for the next five, for the next 10, for the next 20 years. And therefore, certainty for them is a very crucial issue. Now, I also remember from the point of view of developing countries, which Delia was mentioning, I remember we were in Accra. It was a meeting about development. And suddenly Trevor Manuel, then the Minister of Finance of South Africa, stood up and said, how do you spell aid? And everybody looked like, well, you know, AID. He said, T-A-X, T-A-X. And he started like a revival there, you know. And because it was about domestic results mobilisation. So this is true for the developed countries and it's also true for the developing countries. And this comes into a question we've had from the audience for you, Delia, if you don't mind. Do you think there should be an 18 sustainable development goal of fair taxation? Yeah, probably, but if you look at the Agenda 2030 with all the development goals, I think we have enough there to make this real and working. Because it has to do with good governance. It has to do with collective action. It has to do with anti-corruption and rule of law. So if you have all that in place, you don't need an SDG 18 or 19 or whatever it is in order to have this properly done by everybody. This is not a problem just for Europe or North America. This is a problem for the whole world. And we have the tools if we have the commitment of all stakeholders. And I would stress, as Katherine was mentioning, the role of gatekeepers here. Gatekeepers are helping in many cases to avoid tax pain or to facilitate evasion. And we have to have gatekeepers on board, not only in terms of taxation fairness, but in terms of transparency and anti-corruption, beneficial ownership, transparency, and shell companies and all that. And if you see the last scandal of the Dos Santos fortune, the principal actor in this big scandal of grand corruption are gatekeepers. Well, Katherine, that's another point being raised by another member of our audience here, is should we be holding the big accounting firms responsible in this as well and addressing how they do business? Yeah. I mean, I think in Germany, there was recently a case where a major lawyer was accused in a criminal tribunal for aiding and tax evasion. And that's rare. It's very rare that lawyers are being accused. But I think both accounting firms and lawyers have to do some soul searching here and have to think about how far they're going, how far they're pushing the limits of existing rules. And I think I would like to emphasize again the rules will never be watertight. It's sometimes really a question whether you want to enforce the spirit of the rules and advise your clients to live within the spirit of the rules or whether you try to evade the spirit by looking at the formal ways to arbitrage around them. Bruno Le Maire, another question here is saying that national taxation is not the solution. In the end, tax is paying consumers. How do we incentivize tech companies to pay? Do we need to be incentivizing companies to pay this tax? No, I don't believe. Neither in optional taxation, nor in incentives to pay. A tax is a tax. Full stop. And you have to pay it. And the role of the governments is to be sure that the companies pay their due taxes. So it's up to us to define the rules. There must be as simple as possible. There must be fair. There must be transparent. There must be efficient through an arbitrage system. And that's exactly what we are working on. But that idea to have an optional taxation, I do not know any single private company that would opt for a taxation instead of a non-taxation. Fair enough, yeah. I think we can all understand that. Uncle Guria, another question from our audience here. How do we find a fair solution that doesn't only apply to U.S.-based companies? The scope of a lot of the measures that we've heard, for example, the French measure, it does capture mostly U.S. companies there in line with the dispute with the United States. Will this plan discriminate unfairly against U.S. companies? This is not about the companies of any particular country. This is about countries above a certain threshold of business, like the tax that France instituted was about. In fact, the European directive that eventually was not approved, but it was very much along the same lines. So the idea of capturing companies that go above a certain threshold of business is there all the time. You don't capture everybody. And second, it's not only with the minimum. This is, by the way, a French-German proposal. This is the minimum tax idea. And I have to give this in fairness to the source of the proposal. And this will capture not only digital companies. It will capture anybody who does more business than X. And because the principle is fairly straightforward, the principle said, where should you pay taxes? Well, you pay taxes where you do the business and where you generate the profits. Now, let me quote a classic here, this Vladimir Putin. We were in the G20 in St. Petersburg. And he said, if we are successful, this will be the greatest ever revolution in the international tax regime that we have seen in 100 years. Now, the Russians know about revolution. So just to put it in context. OK. We're coming towards the end of the session, so I'm going to come through and ask quickly. Katarina, starting with you. Do you believe having listened to this debate and followed the issue, will 2020 be the year that you think there'll be a deal done? I hope so. I'm a little bit skeptical because I think that multilateralism and cooperation at an international level has been deteriorating over the last years. There's some turnaround that we're seeing. I hope that will materialize. And I think maybe this could instill even more optimism for another round of multilateralism in the future, even in trade, not only in taxes. OK. Bruno LeMair, I'm not going to ask you if you think, because I know that you're optimistic about it. Why do you think you can achieve this before the end of 2020? I'm optimistic for 2020, even if I'm aware of the difficulties. But I fully share what Katarina just said. I think that we have all to be aware of what is at stake behind this question of international taxation. The question is to know what kind of world we want for the 21st century. Either the fight against nations or more cooperation. And to address key issues like climate change, new technologies, taxation. We need more cooperation among nations. That's what is behind that fight for a better international taxation system and a digital taxation system. OK. I'll go briefly. 2020, what about the year of the deal? I'm not pessimistic and I'm not optimistic. I'm optimistic. So we put Mr Pascal Santamant to work very hard. All the 137 countries in the next week and then in the months in between and then July, et cetera. And we get it done. This is what we're going to be focusing on. We have no plan B. We just get it done. OK, Delia Frey-Ruby, are you optimistic the final word? I am in the same line. And we should be having this in 2020. OK. Thank you very much to all of my panelists. Thank you to everyone here in the audience, everyone watching at home. This has been the France 34 debate from the World Economic Forum in Davos. Stay with us. 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