 Good morning, ladies and gentlemen. Very welcome to this Congress or conference. I don't know exactly the difference. I'm dedicated to state aid from a text perspective. This Congress concludes a new project dealt with by Tilted University in cooperation with the University of Antwerp, University of Bologna, and the Institute for Culture and International Text Law in Vienna, especially meant for national judges, because national judges play a very important role in the process of state aid. My name is Peter Essos. I will be the chairman today. I'm a professor of text law at this university, and I'm really looking forward to very interesting presentations and also interesting discussions, because as you will notice, we will ask you also, especially to give us your opinion on the issues dealt with, of course, based on the presentations of our speakers. We live in interesting times, at least if you are a text lawyer, and especially if you are a Dutch text lawyer. Yesterday we had a group theory on decision, which might ruin our fiscal unity concept, unless we change this concept, and we can do it by limiting it, or by expanding it towards or across the border of the fiscal union. This might be a better solution than limiting the possibilities of the fiscal union. And then, of course, we also have a lot of developments with respect to state aid. State aid in relation to main euro and profit ship. One of the questions dealt with this morning will be the question, what is the relationship between the decisions of the European Commission towards fiscal state aid concerning rulings concluded between the tax administration and IP companies from the United States? Is there a connection with the BEPS program of the OSP? Yes or no? If the answer is yes, then the issue you are dealing with today might fade away a little bit. As you all know, member states are implementing BEPS proposals. We have the anti-avoidance directives, and they lead to possibilities for tax administrations to limit approaches of companies to achieve base erosion and profit ship. A very important development is also the U.S. reform of tax starting in the beginning of this year. There is a lot of criticism towards the U.S. president. We are not going to deal with that. But if you look at taxation, you might have a point. One of the interesting aspects is that he has introduced a regime which makes it very difficult to defer the profits of taxation. So most U.S. companies used the system that they stole their profits, let's say the Bahamas or Bermuda, in order not to distribute these profits to the United States because taxation in the United States would only be possible at the moment these profits were distributed. Now, in the new U.S. tax reform, this is not possible anymore because U.S. companies abroad, having all these profit returns, have to pay taxes on these returns against the mitigated rates, but still in the coming eight years they have to pay their tax bill. And this makes structures like Starbucks, I've shown you here the scheme, unlikely in the future, because there's no use anymore to wait with distributed profits. So the question is, will these structures happen again? Then we also know that, for instance, hybrid entities used also by Starbucks are also not really valid anymore. A very important role in Starbucks' question was the position of Alki Limited Partnership in the U.K. For EU considerations, this partnership is considered to be transparent. So if you pay royalties or interest to this Alki Limited Partnership, instance by Starbucks UK or Starbucks Netherlands, in Europe we cannot tax it because it's supposed to be transferred directly to the partners of Alki. And in the end, that is Starbucks USA. But for U.S. purposes, Alki is considered to be an opaque entity. At least you can opt for that, check the box. So for Starbucks, Alki is considered to be an entity. As long as profits were not distributed, U.S. couldn't have taxed. So that was the reason why all these profits, thousands of millions of dollars are all stalled in tax paradoxes. But if you look at the aid debt, you also see regulations limiting the deductibility of royalties or interest paid to a hybrid entity by Alki. So that's also something which will make these sources not attractive anymore in the future. Then we know that there is a lot of debate about rulings. This week we had a letter from the tax administration saying that there would be a new investigation determining new criteria for individual rulings. I never knew that there were so many individual rulings still because we always thought that everything was dealt with by the ruling team in Rotterdam. But still there are individual inspectors who were entitled to conclude their ruling. So the issue is, looking at the U.S. tax reform, looking at the anti-bets measures, will decisions about state aid still with respect to IP companies, will they still be expected for the future? I think this is an important question. Personally, I don't think they will disappear because if you look closely to these decisions, it's not directly aimed at beps, but it's mostly aimed at the way transfer pricing is developing in these cases. Is the ruling on transfer pricing concluded between Starbucks, Reynolds, and the tax administration is this ruling at arms lengths? And of course you can say, well, why did they choose these cases? Because you have the debate on beps, but you will also have this problem if beps is not there, but you have to apply transfer pricing with IP companies. And there are other cases in which you also see a problem with respect to international tax law principles, concept of residency, or better to say, double non-residency in the Apple case. If this is true, then the concept of state aid might be of influence for important international tax principles. So this is not only a conference which is important for the actual problems, but I think also for future problems with respect to the future of transfer pricing.