 Welcome, everyone. I'm Raj Kumar, president and chief of DevEx and delighted to be moderating this session today. And in fact, like many of you watching and seeing that video, I wish I were in Japan too. And this session, hopefully one day we'll come back live and in person, but this is not a bad substitute. And in fact, that's really what we're here to talk about, how our lives and events like this have changed so dramatically during the pandemic, how much has moved digitally, virtually and how do you tax that appropriately? This is not an academic conversation. This is a very real live immediate discussion that has practical implications today for governments and for companies and for consumers all over the world. So I'm really delighted the world I can inform has brought the conversation to this summit and brought together such an incredible group of panelists to have this discussion. Let me just tell you who's here and then we'll dive into the conversation. We have Cedric Oh, who is the minister of state for the digital transition and electronic communication of France. Welcome Cedric. We have Josh Calmer, who's the head of global public policy and government relations at Zoom. Barbara Angus, the global tax policy leader at EY and Sharon Burrow, the general secretary for the International Trade Union Confederation. This is a group of panelists joining us from all over the world, which we can do because we're virtual. But governments around the world have said, look, so much of the economy is moving virtually. How do we appropriately tax this? The OECD is actively working to create a unified approach to it. They say maybe by the summer, by June, there will be such an approach. But before we get there, many governments have said, we're not gonna wait. And there are digital services taxes that are called DSTs coming online in many, many places. Others being debated in other countries. There's pushback, the Biden administration just announced they wanna put forward tariffs. I think I've valued about a billion dollars on a number of countries that have these digital services taxes. So this is, as I said, a very live, active debate. And I wanna begin with the minister of state with Cedric, if we can, because your government and you personally have been so active in this debate. And just to get a sense from you of why. Why are you pursuing an agenda of digital taxation? Why do you think it's important to do? Well, thank you first for having me today. And I do think that the debate that we're having today is very important both from an economic point of view but also from a democratic point of view. Well, you mentioned the high speed digitization rate of the economy and the fact that for some specific players, which are highly digitalized, they have been reshuffling the way value chain are working, the way the value is created and distributed within the country that they operate in. And they have been putting into pressure the original principle on which a taxation was based, which was that you were paying tax for public services, especially in the countries where the value was created and where the service was provided due to the way the digital economy is working. Those principles have been squeezed by the digitalization of the economy and by especially some very important stakeholders which are highly digitalized. On the same time, we have seen with the COVID-19 pandemic that the question of financing the public services, financing a healthcare system and so on is something that we have to take care of. And this is why France has been advocating but with many other countries and the European Union especially, to create or to reset the principles on which our international taxation system is worth. Obviously, and you mentioned it, since we're talking about something that is basically international, the solution should be multilateral. We need to find a multilateral solution. This is why we have been backing for many years now a solution at first at the OECD level, if not at the European level. But what we cannot condone is the fact that there is a huge democratic pressure on those questions of sharing the value on taxation. This is why some countries in the meantime until we are able to find a solution at the international level have decided to take the initiative. France is one of them, but this is not the only one. And if you like, look at the multiplication of the countries that are taking initiative at that point that will give you a hint on the democratic pressure that is existing within those two. So what we said is that we would take the initiative, but there would be a sunset close to some extent. The day there is an international solution, we hope at the OECD level, and we noticed very positively the latest declassion of the United States, it would replace the French taxation. Well, as you say, people do want this. I mean, some taxes are unpopular, but depending on the country and on the population, there are many people who would be supportive, I think, and see this as a political positive to put forward taxation on digital services, especially when you think of how concentrated the global digital economy is among a few major players, how many of them are based in the United States. And even before we got to this point, there are so many companies, major corporations that pay less tax than many governments think that they should and have moved around the world in order to find the best places to be taxed. So I guess maybe we can bring in Josh into this discussion. This is very meta in a way, Josh. I'm talking to you on Zoom, you work at Zoom, and we're talking about taxing companies like Zoom. How do you think we should think about a digital services tax? What impact would it have on Zoom, on consumers who use your product? And can't you understand the sort of direction the minister's going as well, saying, hey, we need revenue for our health system and our education system, and we can't just wait forever. We need to get to the point of a reasonable tax on companies like yours. Yeah, thanks, Raj. Minister O makes a lot of really important points. And I say this in my capacity of my current role with Zoom, but also my prior one, representing the global tech sector as a whole. Some of the points he made, and it was evident in the introduction to this, are just that the world's changed unimaginably over the last 20 years. The extent to which services are being provided digitally across borders is remarkable. And it is absolutely the case that the notion of permanent establishment, the notion of a physical place of business as sort of being the anchor for allocating taxing rights has lost some of its utility. It's still an important concept. It's still an important fixture in the set of international tax norms. But I think that there is certainly an appreciation within Zoom. And I think across the global tech sector as a whole, that digitization has legitimately changed the playing field and that governments have legitimate questions about how to respond. From our perspective, the important things are twofold. Number one, that we look at digitization as a whole. Certainly there are some companies that are very significant players. Sometimes Zoom is included in that bucket. Sometimes it's not. But we're dealing here with a larger phenomenon where it's not just internet platforms but services companies of all kinds, providing services across borders digitally, often with no physical place of business. And so the phenomenon goes beyond a small group of admittedly very important countries. The second point is that it really does have to be multilateral. And I commend Minister O and Minister Le Maire and the French government for their leadership in the OECD. This is, if there were ever an issue that was just fundamentally international where the cross-border interdependence was so undeniable, it's this. Because ultimately, whether you're looking at revenue or whether you're looking at income, there's a fixed amount of money in the world that is the subject of this discussion. And we have to have a principled, coherent, consistent way to determine how to allocate tax and rights with respect to that. And it's not just the global tax system that's at stake, it's really the concept of multilateralism, the concept of cooperating together as the Japanese government said so well to meet the challenges that we all face now. There is some danger in this though, right? And Sharon, I want to bring you to the discussion. There's some danger that until we get to a unified multilateral agreement, maybe it takes a lot longer than's expected, that countries will race to do what their populations want, add new taxes, create complexity, create barriers, slow down the innovation, make this more difficult. Do you worry about that as someone who I think believes in a digital services tax? Talk to us about why you think such a tax is important and how do you think of this issue that potentially there are gonna be some unforeseen consequences if we go down this road? Well, we have to have a multilateral approach. There's no doubt about that and the minister and others will make that point, I'm sure. If you look at the current situation, it's fair to no one. It's not fair on a competitive basis for companies who operate in the commodities world. It's also a product world. It's not fair for those companies operating in great, for the, sorry, the governments who are seeing tax revenue fall, where companies increasingly operate in a gray zone by suggesting their product release services and digital services of that. And it's absolutely not fair to individuals who depend on their governments for, in this current context, recovery, building recovery in New Zealand's, but also for those essential public services, universal social protection. Ultimately, business can't operate in this uncompetitive space, nor can democracies regain or contain and regain trust of citizens. So we must have a digital tax. At the moment, we absolutely support the OECD tax agenda, particularly Pillar 2, which would go a good part of the way by making a universal base, 25% we would hope for corporate taxation. And there's some hope with the US just having raised its tax base to 28% for corporations that this might actually come to fruition. At the moment, most corporations or their advocates are arguing a much lower rate, but that will be played out at the G20 and we absolutely support and think that the policy setting, minus perhaps the rate, is actually ready to implement by agreement. However, on the digital, the taxing of digital services, but digitalization broadly, then we are still seeing Pillar 1 as not having enough ambition and as being too complex. We hear people talk about the complexities of double taxation, but we have to get the mechanism right. And so I understand and we support countries who are acting in the interests of their own citizens, absent a global approach, but in the end, we have to have a global approach. It's that simple. But you can't have a loss. You know, already we've got something like a $400 billion tax loss through tax evasion in OECD countries alone, let alone what it would mean if we're able to have the kind of shared, you know, sort of fundraising capacity of taxes fair taxation, indeed to help developing countries. So it is urgent, but we must get it right. Thanks for that, Sharon. Barbara, I'd love to get your take on this for the people following along. You know, we've introduced you as a senior advisor in global tax policy at EY. You were until recently the chief tax counsel on the House Ways and Means Committee of the Long History working on Capitol Hill as an expert on tax policy. So thinking about that kind of bigger picture view you're able to bring to this discussion, Sharon mentioned that, you know, this is one part of a broader theme of many global companies not paying sufficient taxes according to their own governments where they're based, people shopping around for the best tax environment. There's a long history of countries competing against each other using tax policy. Do you think it's possible that we can get to a true multilateral digital services tax where everyone sort of holds hands around the world and this really works? Or what do you think is the likely scenario for how this will play out? Thank you. It's a pleasure to be here and to be a part of this important dialogue on a really timely topic. I guess I will start by joining the chorus for a multilateral approach. I think that's critically important. I also think it's important to maybe to step back and talk a little bit about the difference between what the inclusive framework is working on and what a digital services tax looks like because they are very different approaches to digital tax. The inclusive framework proposal and it's pillar one of the OECD G20 project is has at its core the traditional architecture of the international tax system and it involves efforts to make fundamental changes to that historic architecture. It is centered on country's corporate income taxes and it contemplates changes in how taxing rights over global business income are shared among countries by with the game of allocating a greater share of income to the country where the market or customer exists greater than the traditional principles would have allocated but it builds on and supplements those traditional principles and it really involves two of the major building blocks of the international tax system. One is the concept of nexus. When does a business have a sufficient connection to a country to fall within its taxing net? And that traditional concept has been permanent establishment which has a focus on physical presence and this effort would supplement that and create a situation of taxable nexus where there is no physical presence. The second of the building blocks is on the allocation side. How to determine in a complex global value chain where value was created and how much value was created in each location. And in this aspect, the effort seeks to supplement the traditional approach of the arm's length principle by adopting a somewhat more formulaic approach aimed at allocating a portion of these profits to the place where there is nexus. And the object is a coordinated approach to ensure that there isn't double or multiple taxation which would be a real barrier to global activity. On the other hand, digital services taxes are taxes on gross income or gross revenue not on income or profits. And in that way, they're a blunt instrument and can apply in situations where there is no net profit. So countries have taken different approaches in defining the activity that triggers a DST and that means there are circumstances where the same revenue could be subject to multiple DSTs. It's also important, I think, to note that the inclusive framework proposal isn't limited solely to digital business activity but also would allocate more taxing rights to the market country in the case of consumer-facing businesses that are not digital. And so that's another difference between the two. Both of these, both the inclusive framework proposal and the digital services taxes we've seen adopted have roots in a European Commission proposal from five or six years ago that paired the two contemplating a digital services tax as a temporary measure that would be in place only while the coordinated corporate income tax-based approach to less blunt instrument was being developed. And I think that's really what we've heard today and this focus on the need to do the work to develop the multilateral and coordinated approach. And of course it does put pressure on that multilateral approach when you put forward these unilateral DSTs that does maybe create the political pressure needed to get to a multilateral approach. Minister, oh, maybe you can jump back into discussion. I understand that Google in France, one of the ways you've approached digital services taxes to tax advertising. And I understand that Google has said recently, well, we're going to raise ad rates in France in response to this. And I guess I wonder how you think about this is just maybe one example of how you're going to approach your unilateral activities while at the same time working to get to a multilateral framework that works for everyone. Well, let me be quite straightforward on that question. Obviously we do regret Google's decision as well as we regret the same kind of decisions that had been taken by Apple or Amazon to make their customers, be their business customers or private customers pay for the tax, which was obviously not the principle of what we did. Hopefully the French tax, as I mentioned, will only be a temporary one and we'll be able to reach an international agreement. But that tactical decision from those companies might be dual side, if I may, because that could bring a lot of evidence if there is no churn within their customers that they have a market power that is justifying all the initiatives that are being taken as far as antitrust is concerned. I don't know any normally working market where a company could raise its fee. I don't think that Zoom would be able to raise its price without having a churn within its customers because of the fact that there is competition. So as you know, there is a lot of antitrust discussions those days and if those company are able to raise unilaterally their prices without having any impact on their customer basis, that would mean to some extent that what we are advocating for is that they have a footprint which makes them, which put them in a non-legal politic position or in a monopolistic position is something that is justified and that is justifying the initiatives that are especially taken at the level of the European Union. Yeah, that's a powerful argument and I think it does point to the fact that there's multiple things happening at the same time here, right? There's a move to make a better multilateral corporate tax framework across industries, not even just digital companies. Then of course there's the digital environment but then at the very top there are a few companies, many of which are US based, which have large market presences in many other countries and I think part of the idea here is to try to target all of these different purposes and I guess maybe this is a good chance to bring others into this. I really wanna open up the discussion so please feel free to jump in if you have a point you'd like to make but Josh do you have a reaction to what you heard from the minister, his provocative point that look pricing here also connects to issues of monopolistic power and these things are not disconnected. Yeah, I mean I think there's some very real competition related in the US antitrust related questions happening in the global economy right now in the technology sector and in other settings and I could speak from Zoom's point of view as still a relatively small company that is in a relatively competitive environment. We're following those issues. We care about the outcomes of those discussions but I think the question here we all agree I think on the broad theme that the economy has changed in ways especially through digitization that make reexamining the global tax system appropriate but we may have some differences tactically on how to get there and so when we look at the tax debate and we see the proliferation of unilateral measures we can observe both from our own experience and from the experiences of the technology sector in particular as a whole a few challenging things happening that hopefully we'd all want to avoid. The first is the prospect as Barbara mentioned of double or multiple taxation. If you don't have clear rules of the road agreed among countries that are essentially battling over the same quantity of revenue or profits you have the very real prospect of that happening. The second is it's a blunt instrument when you tax revenue, right? Because that could be taxed in multiple jurisdictions at the same time. It's not just about what comes to the bottom line. Yeah, and a lot of then this relates to another of the points which is that some of the DSTs out there don't have minimum revenue threshold. So you have small companies many of whom do not make a profit for many years who potentially would be within scope and be taxed on revenue that is not part of an overall profit making effort. And so to the extent we want to incentivize small innovative companies entering the scene all over the world, which I think we do we have a potential penalty there. A third point is administrability. It is no small feat even for relatively large company let alone the largest ones to sort of reposition and re-engineer their internal processes and their financial reporting approaches and everything they need to do to comply with greatly varying rules from market to market. So there's a deadweight loss there that occurs. And then I think that the final point goes beyond tax and it goes to multilateralism and global cooperation more generally. I mean, as we can see my old employer the Office of the U.S. Grade Representative has been looking at these issues closely for the last couple of years. These kinds of disputes about how to tackle shared global problems when individual markets depart from multilateral approach it affects the larger global environment as well. It affects trade policy. It will affect, well, I won't say it will but I think it's reasonable to expect that it would affect things like how we fight climate change. Truly shared problems just like taxation that we need to be working together to address. And just one final point. This is a lot of U.S-based companies have been the focus of this debate but ultimately if you look at the measures being enacted around the world there are measures in Asia that are affecting European companies. Measures in the Indian measure affecting Japanese companies and so forth. And so we all have a state. We all wanna encourage innovation, encourage small business, encourage employment and growth in every market but the unilateral measures really create challenges for us in doing so. Barbara, maybe you can pick up from there what's your view at these unilateral measures? I know you talk quite a bit about the inclusive framework and I'd love to hear how you think we get there. What do you think of these unilateral measures as a stepping stone to a multilateral approach? Is that the right way to look at this? Well, I guess a couple of comments. Some of the digital services taxes that have been enacted were enacted with a sort of a natural sunset or a phase out or were linked to the work in the inclusive framework and so from the outside had this intention that they would disappear when there was a coordinated solution. That's not true of all of the digital services taxes. And I guess I would, I think Josh said it very well. The complexity that's involved in preparing for and complying with these taxes and managing them all around the world is huge and it's not less knowing that the tax may only be temporary. There's also a concern about when you put a tax in place as a sort of a temporary measure to be replaced by something that's still being developed once that's developed will in fact to the original measure be eliminated is a natural worry. And so I think and the nature of these taxes really are the uncoordinated approach and the overlap and conflict are I think a real concern and create real barriers to activity. And so as you said earlier, it also is creating significant pressure on the inclusive framework process and the target for that process is agreement on an approach as you said by mid 2021 potentially by the July G20 Finance Minister's meeting. That's an ambitious target, but there is significant momentum behind the project. And the inclusive framework, despite the challenges of the pandemic has made a lot of progress on the technical work related to both the pillar one approach to digital taxation and beyond. And also the second pillar which Sharon mentioned which involves the establishment of a global minimum tax system and is not directly connected to digital taxation. The inclusive framework released detailed blueprints on each pillar in October and held a public consultation. There were thousands of pages of technical comments submitted by stakeholders and so the work is advancing. There are significant political issues to be resolved and additional technical work to be done. Maybe the most significant open question involves the scope of the new rules. In the end, will they be limited to digital activity or will they apply more broadly as it has been contemplated to date? Is there a potential for a phased in approach, one that starts with digital activity during an initial period and then expands to cover and encompass other types of business in later years. There continues to be a question if there's an interest in focusing on digital activity. The US government has been quite vocal expressing concern about that and the difficulty in the view of the US government in appropriateness of trying to ring-fence digital activity for a very different form of corporate income taxation than other activity. That involves a really difficult definitional issue is what is meant by digital activity. Certainly we know some digital activity but every day all businesses are getting more and more digital. And so the most sort of commodity-like business today has a growing aspect of the business that could be viewed as being digital. It's just the nature of the globalization and digitalization of the economy. And so that creates challenges in trying to do something that is narrower. I think there is one- I want to share, so go ahead and make that last point. I think one outcome could be a high-level agreement in principle this summer with plans to continue work to ensure that they develop the details of model legislation and model treaty provisions. I guess I would say that as a final thought I think it's really important that a consensus on this and that the multilateral activity be grounded in a common understanding of exactly what the rules are to be and how they're to be implemented because this is an effort that requires coordination not just in the design but in the ongoing implementation on a day-to-day basis. Sharon, especially given how fast-moving, as you say, many companies, you might not consider them digital now. They're moving in that direction. Sharon, I'd love to get your take on some of those questions that were posed by Barbara and I do want to mention all those who are following along. If you want to submit questions, please do so. We'd love to take one or two in the time remaining. Go ahead, Sharon. So I think Barbara's right about the convergence. You can't ignore the fact that what's Amazon? Is it a product market? Is it a digital company? What is it? And yet it's explosion amongst the other things of profit. Yet have a look at their tax payment during just the period of the pandemic is extraordinary. So we have to go back to first principles. Should a company pay tax where it's actually earning money? Yes. Should it be that everybody plays a fair share? Yes. We've seen decades of tax lawyers, company lobbyists. You know, look at the illicit flows on commodity and product markets out of developing countries. This can't go on because we'll never build trust in a world that is governed by, you know, sensible multilateral rules if we don't actually include everybody. And I hear the arguments about revenue versus profit but I have to tell you I'm a skeptic because I've seen companies manipulate profits. So they'll tell you they'll move them around till they're making profits in no profits they say in a low tax environment. Well, that's got to end. If we're going to have decent companies and there are many out there having a fair competition floor then let's actually get it right. So I think Barbara's right. For us, pillar two, I'm not putting words around this bit in your mouth Barbara, but pillar two on a base corporate tax ready to go let's get the rate agreed, let's get it done. Then if we agree on a framework but not an exclusive framework that does exactly what Barbara says let's companies fall through the cracks, you know, narrowly taxes, digital services that don't include the explosion of online capacity that small companies don't have so they're forced to use larger company services making them unprofitable or uncompetitive themselves. Let's get a shell of principles agreed, a very fast timeline and let's get it right. Thanks Sharon. As we kind of wrap up here we just have 10 minutes left in the session. I'd love to get some final thoughts from each of you and maybe minister. Oh, you can just speak to what some of the critics would say about the approach that France has taken, right? You'll hear people say that this is owners especially in small companies that administering these taxes ultimately you're gonna pass it on to consumers we saw in the case of Google. You'll hear people say this is gonna become a tit for tat approach where countries are simply pushing and you're gonna actually undermine the multilateral approach and then maybe even innovation gets undermined here because ultimately the taxes are directly targeting the most innovative part of the economy. How do you think about those challenges that I'm sure you hear and have heard in the debate in France and in the multilateral institutions where you operate and what do you say to them? Well, what I would say is that first we have to enter the democratic two question. The first one is economic but the main one is democratic and I think that has been shared by all the participants. There is a huge democratic pressure to adapt the way our taxation system is working to that digital era and we have to do this we have the responsibility to do this. With this hinder competition and innovation I don't think so. As far as France is concerned we focused the tax on some specific players and we did not decide to reshuffle all the tax system for the digital services tax but we want to focus on companies that are relying on network effect and all these kind of things and highly digitized players with an important economic footprint making a hundred of millions of revenue in France so I don't think that it will hinder competition and hinder innovation for emerging players that can develop without paying the tax and to make a final statement and to connect with the discussion that we have I think that we have to fix the taxation issue but the taxation issue is only the emerge part of the iceberg and the part that we have to solve is the way that economy is working the way giant players have emerged with oligopolistic and monopolistic stance and positions and we have to be able to re-input competition and free market within the way digital market are working this is something that is work on both in the US but also in Europe and I do think that this is the most important issue that we have to solve from a multilateral point of view but also within the US and within Europe in the years to come Thank you minister maybe I can go to you Josh and we just have about a minute each left for each of you what do you want to see out of this debate out of this pretty fast moving policy change and what worries you what do you think needs to be carefully avoided? Right, well I think I would just summarize what I've said in previous comments that we'd really like to see a multilateral solution with all the players at the table leaning into the idea that the way the economy is now it demands answers to these questions we want to avoid on the flip side the unilateral approaches that so many markets are taking for the reasons I and others have laid out and then I think a third piece that we haven't talked about yet is just the this debate one way to look at it is that it's thinking about tax policy as a stick in a way and that may be a little bit unfair tax policy has an important role to play but is there a way to look at tax policy potentially as a set of carrots ways to encourage activity we want to encourage like innovation like actual physical investments in certain markets I think that's a conversation that Zoom would be very eager to have look we're committed to the growth and development of markets around the world and working with governments to get there so that's the spirit in which all these comments come out and we just really want to find creative coordinated multilateral ways of getting there Yeah that's a great point about the carrot versus the stick and how tax policy can really do both things Barbara you spent your career designing tax policy with those ideas in mind what are your parting thoughts to us as we try to move forward on this digital services tax debate This is a really important debate and one that it is a very positive thing that it's a debate that's happening in the inclusive framework that includes 139 jurisdictions around the world so it really is a global discussion that in today's world is essential I think it is important that as these policies are developed that there be a commitment to ensure that there is a real coordinated agreement so that competing tax policies or overlapping tax policies don't become a barrier to global trade and investment and I think it's also important to recognize that the costs that are incurred by businesses particularly related to innovation and that those costs need to be recognized which is the importance of an income tax and also that there can be many years of costs before there are profits and so it is also important not to look just on an annual basis but to recognize that that annual period is artificial and the costs that were incurred for many years before need to be taken into account so I think all of those things need to be part of this global discussion Yeah, that is one of the complexities with especially software businesses and often enterprise software where you know that the future revenue streams are based on a lot of upfront investment and years of losses to get there and designing tax policy that addresses that does sound like a real complexity Sharon, your final thoughts on what you're hoping to see us get to as we come out of this? Well, I think first of all, we've all made it clear the ultimate goal is a multi-lateral approach that's fair to everybody and I just caution on, you know we're big supporters of industry policy innovation but I ask you to look at the history corporations have taken more and more of the treasury pies in every country for what is actually investment in their own business model to the point where the trust is broken in those countries and trust in the big tech companies is particularly broken because of the explosion of profit versus the taxation they're paying or in fact the wages they're paying you know in the case of some of the big corporates or the respect for freedom of association particularly Amazon and the like but I just want to finish by saying I support minister O entirely if you can't get action on a global stage initially you have to do something in your own country to retain and build trust and if you can't, if you can make that conditional indeed on a block like the EU and I would say we totally support the EU developing rules America will develop rules and I'd support our unions and other actors saying in the absence of a multi-lateral approach that's logical and it's also important because no one's touched on the geopolitical power but if you look at countries like China using you know tech development and governance and the trade wars that are that's eliciting then we need to actually make sure there are regional blocks big national company blocks whatever it takes in order to negotiate a settlement but let's see if we can do it through the OECD let's make that happen the G20 adding to that let's make that happen but I totally understand governments because people will demand it and that's democracy and indeed groups like the EU, the US etc actually building a base because citizens are demanding it trust is broken and frankly our democracies will demand the same and finally can I say we support the companies that are not lobbying in their own interests there are too many still lobbying to evade tax rather than indeed to pay a fair share and that's where we want to see the end game Well thank you for that Sharon I think you really helped to wrap up and bring us full circle in a way you know Cedric, Minister Cedric said at the beginning that this is really a question of democracy and what people want you talked about the issue of trust in some senses is a very technical conversation for those of you following along around the world about you know how precisely do we target digital companies how do you define them what's the appropriate way to tax them how to make it work multilaterally but it's also a fundamentally political and democratic question as you just say Sharon it is about trust and when that trust has been broken it makes this job that much harder and the promise of a multilateral approach that much greater if we can actually get there so I want to thank all of you for a really fascinating discussion for an ambitious discussion I think and thank all of you who joined us from around the world so again my thanks to Minister Cedric Oh to Josh Calmer to Barbara Angus and to Sharon Burrow thank you so much for a great discussion and I want to bring in now if I can Sean Doherty who is the head of international trade and investment at the World Economic Forum just to take us out of this session and to talk about the next steps from here Great thanks a lot Raj really I just wanted to on behalf of the World Economic Forum thank you and all of the panelists for really a great conversation the forum's multi-stakeholder community will be exploring this topic in some depth over the coming months and I think this discussion has really been a great way to get us started off into the next phase so what we'll be doing is we'll be looking at how digital services taxes and other tax policy changes are affecting digital trade affecting companies business models and competition and inclusion as well so what we hope to do is to be able to advise on how to make policy more effective and more coherent and connect importantly between tax policy between trade policy, antitrust policy and more so I do invite everybody who's joined the session today to please do get in touch with our trade team if you'd like to contribute we'd love to hear from you and again thank you very much to our moderator, to our panelists and to the audience today thanks everyone, goodbye