 My presentation is just seeking to highlight some of the issues that are probably relevant to this session, which is taxing the digital economy, what does the future hold? It builds on a number of the earlier presentations and comments that are made. As has been outlined, the current tax environment for the digital economy is one of immense scrutiny. It's a major element of all economies, and given the immense scrutiny, it's clear that the current tax rules may not be adequate to address the tax matters that arise in the digital economy. In particular, how activities carried on in the remote fashion are taxed, and how indirect taxes on principally business to consumers are dealt with in particular areas or matters of concern. So the future, what does the future hold? It's clear that there's going to be a change in the tax environment that applies to the digital economy going forward. At present, there's uncertainty as to the extent and impact of the change. As we've seen earlier, the BIP project is ongoing, and it will be the end of next year before we have the final reports, and even then there will be a question of how those are going to be implemented. It, based on the comments that have been made so far, it looks as if new approaches will be taken in particular in relation to taxing the digital business in a number of areas. And these are likely to have an impact on how business may be undertaken in the digital economy. Clearly, the current environment we're dealing with is going to change, how that impacts on how people will actually engage in business is something that remains open. It looks as if there will be a potential for a higher tax burden. The reason for that is it's clear that some of the changes that are proposed will result in profits being allocated in different places, and thus higher tax rates may very well apply. In addition, as you've heard before, the key issue in relation to profits not being taxed is one which has been focused on, and that is likely going to increase the tax burden for some of the businesses in this space. In addition, some of the proposals as have been highlighted will result in additional administration being undertaken by companies to provide additional information to tax authorities so that they can fully consider the way businesses are structured. The current rules that apply in international tax, which rely on the tax treaties based on the OECD model convention, typically do not result in tax being paid where a person doesn't have a physical presence in the country in which they're dealing with. And thus the current definition of PE as has been outlined may not be fully appropriate for the digital economy. It is possible for companies to seek to minimize the taxable presence in which they operate in, and the media focus that we've seen recently is tended to be on operations which have been structured to facilitate that. So very often you'll see comments being made of how particular businesses that have operations in Ireland book most of their profits here, because very often the other markets they're dealing, they do not have physical presences there. And under the terms of the double tax agreements, they're not liable to tax those jurisdictions. In addition, a major part of the profit that now arises in the digital economy and in the wider economy relates to intellectual property. An intellectual property is an asset that can be moved. It doesn't necessarily have to be located in a particular jurisdiction. And by moving the intellectual property, people can seek to achieve a particular tax result. In addition, as we've seen with the way e-commerce has evolved, there can be a difficulty in determining where people are actually acquiring goods, and according to how value-added tax or general sales taxes have to be dealt with. An interesting comment from one of the reports that I'll be referring to later on the digital economy notes that the digital economy itself doesn't create unique BEPS issues. But some of its features can exacerbate the BEPS risks themselves. So of itself, the digital economy is not something that's a direct focus for BEPS. But just the nature of some of the activities that are carried out means that some of the other matters that are a focus of BEPS are of particular relevance to businesses in the digital economy. I think when we're looking at this particular space, it is worth noting, and this has been referred to before, that a lot of the structures that are in place have come about because of domestic tax rules and particular jurisdictions. And it is the case that most countries, if they have a domestic tax regime that will confer some benefit, are quite happy for that tax regime to be used. Notwithstanding the impact it may have on other countries. I think one of the interesting things in the whole BEPS project and the approach that's now being undertaken is that most countries or all the countries that are partaking have had to come to the table on the basis that they are all going to address particular issues in their own tax regime and rules going forward. And it will be interesting to see when BEPS is adopted, to what extent the domestic rules in particular countries will end up being changed. So the BEPS, as people will be aware, is the main driver to change in this particular area. Having said that, it is interesting again to note from the document in the digital economy the following comments. And that is that they do acknowledge that the ability to maintain some level of business connection with a country without being subject to tax on business profits earned from sources within that country is a result of particular policy choices reflected in domestic laws and relevant double tax treaties and is not in and of itself a BEPS issue. So a lot of the structures that are subject to criticism about present don't derive from BEPS per se. It arises from the existing tax treaty and the domestic rules that are applied in a particular country. And then in relation to a local subsidiary or a permit establishment that generates little profits, where these structures accurately reflect the functions performed in each jurisdiction, the mere fact that business functions needed to conduct business in a particular country may be more limited in one type of business than in another does not raise BEPS in and of itself. And the key message here is that even after BEPS is finished, it is still likely that for certain jurisdictions, they may not be looking at a situation where there's a major amount of additional profit that would be allocated to those jurisdictions. That the key issue that is still accepted is that there must be real economic activity carried out in the jurisdiction to justify profits being allocated there. So as people, I'm sure aware, BEPS action plan provides for 15 actions to be finalized in three phases. We've already had the first set of reports in 2014, another set due in 2015, and final set in December 2015. These are some of the recommendations from the first set of reports that the key ones to the digital economy are primarily to do with recommendations regarding design of domestic tax treaty measures to prevent abusive treaties, changes in the transfer pricing rules in relation to intangibles, and changes to transfer pricing rules in relation to documentation requirements. The other reports have some impact, but they're the main ones. In relation to 2015 reports, a number of these are additional reports on similar areas. Again, the key again is to do with the permit establishment status, and also in relation to the transfer pricing rules in relation to risks and capital and other high risk transactions. And the final set of reports, again, focus in on transfer pricing rules to limit base erosion, the interest deductions, and other financial payments, and revision of existing criteria to counter harmful tax practices more effectively. So the initial action number one on BEPS was to have a report carried out addressing the tax challenges of the digital economy, and as I mentioned, Mary was part of the panel that prepared that report. The conclusions of that report did not recommend a separate digital economy tax regime. The expectation is that the digital economy is part of the normal economic activities that are carried out, and so it should be taxed under the existing tax regime that would apply to other activities. The report does acknowledge that digital economy does not generate unique BEPS issues, but some of its key features exacerbate BEPS risks, and BEPS risk will be addressed in the context of the BEPS project itself. It notes the intention to restore taxing rights at a level of both market jurisdiction and the jurisdiction of the ultimate payment apparent. It also identifies a number of specific issues that arise from the digital economy that warrant attention from a tax perspective. The key one is probably that core activities cannot inappropriately benefit from an exception to PE status or artificial arrangements in relation to sale of goods and services. And this is a key issue that's likely to come up in the context of the digital economy where businesses that currently are able to successfully trade in other countries without having a taxable presence there, the expectation is that that will change. It also identifies the importance of intangibles, the use of data and the spread of global value chains and their impact on transfer pricing. Possibly the possible need to adapt CFC rules for the digital economy. CFC rules, which are controlled foreign company rules, typically are applied at the jurisdiction of a parent entity to attribute back profits, which may be earned elsewhere. So again, in relation to some of these proposals, they do come back to domestic rules in home country jurisdictions being adopted or applied in order to bring about a particular tax result. And finally, it's noted that there can be particular issues to do at VAT in relation to either end consumers or bodies that are exempt where VAT is a cost, that there can be issues arise from the provision of services to such entities in the digital economy space. So the report also notes that there are broader tax challenges that need to be considered in a wider forum. Issues related to the nexus, what should a company's connection to a particular country or market be? Data, how should data be treated in the context of tax? Is the acquisition of data, should that be looked on as an activity even if it's not subject to a payment? Characterization of particular matters for direct tax purposes? That on business to consumer issues. And there is going to be a supplementary report due in these issues by December 2015. So as I've indicated, the report suggests that taxation in the market jurisdiction should be restored by preventing treaty abuse and preventing artificial avoidance of the PE status. Taxation in the ultimate residence jurisdiction should be restored by strengthening CFC rules. Market and residence taxation should be restored by neutralizing the effects of hybrid mismatch arrangements and by limiting base erosion via interest deductions and other financial payments and by countering harmful tax practices more effectively. And then seek to have transfer pricing outcomes in line with value creation. As an overall summary, people can see that there's a focus here on changing the permit establishment rules that are in the treaty so that they more effectively apply to the digital economy. Having a greater focus on transfer pricing to ensure that profits are correctly allocated. And finally then considering abuse of tax treaties to ensure that tax treaties cannot result in no tax arising in particular circumstances. In addition to the matters identified in the report in the digital economy, the other matters that are included in the BEPS reports which may impact our measures to counter a harmful tax practices, tax treaty measures to prevent abuse of tax treaties. And as people may be aware, there's a proposal that a limitation of benefit laws similar to those used in most U.S. treaties should be introduced into the general OECD treaties. Changes to transfer pricing rules in relation to intangibles in relation to documentation requirements. Again, as was noted earlier, in order to try to ensure that particular tax practices are identified by tax authorities, there's proposals that there should be ongoing information provision to all jurisdictions that companies may be engaged in in relation to transfer pricing, what the structures are and what they actually do in those particular countries. And new rules to limit base erosion. That's new rules to deal with the allocation of profits away from particular jurisdictions. So the position going forward which will be relevant to digital economy is that there are major changes on the way. So for existing businesses, it is likely that their tax profile will change as and when these measures are adopted. Based on the reports, we can see the direction things are moving in, but where we'll end up is not clear. Because again, as has been indicated, while these measures may be adopted at OECD level, the question will then be how they'll be implemented in particular countries. The core challenge will be the resolution of how taxing rights are allocated to resident countries and source market countries. There's uncertainty in how profits related to intellectual property may be impacted. As has been indicated, it's a very difficult area. And how much profit should relate to intellectual property or some of the arrangements that are currently in place as to who carries risks, whether they're acceptable, is something that's still open to discussion in the base. And there's clearly going to be an increase in the administrative burden for businesses in this space. Where are we going to end up? As I said, it's uncertain. The reports give a fairly good indication as to the direction we're going in. It's likely that resident countries will be allocated corporate taxing rights with source countries having a local taxable presence recognized for certain core activities and for collecting VAT. It's not clear what the impact of the limitation of benefit clause will be. Like where people have encountered this dealing with the US, you tend to have to deal with the rules that are present in the US and whatever country you're dealing with. Here, it's likely that you'll have to deal with the particular provisions in the context of every country you deal with, where there may be different meanings attributed to matters such as active conduct of business in order to determine whether you can avail of a treaty or not. As I say, the key will be how matters will be addressed by individual countries. What issues will arise for existing operators? Because as we've noted, we've been quite successful in this space. So for existing companies that are facing these matters, what issues arise? Well, there could be a possible requirement to alter existing arrangements to minimize the increased administrative or tax burden. The existing arrangements that people have put in place have been by reference to what the current rules are. To the extent the rules change, there are likely to be economic drivers as to why people might seek to change some of their arrangements. There may be tax and other costs associated with the alterations. So there may be direct tax where existing contractual arrangements have to be altered. There may be direct tax costs where operations need to be transferred. And there may be an impact on in-country operations that people actually have. People may actually form a view as to whether they may actually want to increase the presence in a country or may actually want to reduce the presence in the country. There would be a requirement for new systems to address the increased administrative burden that it looks likely to arise. What will be the impact of this in Ireland? Well, it's clear that there would be some impact because for some of the companies here, their tax profile is clearly going to change. As I say, the key is going to be in what will ultimately be agreed. As a small open economy, you wouldn't anticipate this having a major impact on the domestic base. However, for Irish companies that are looking to engage in international markets, these new rules and presence and requirements will increase both the administrative burden and also increase the likelihood that they'll end up with profits being taxed elsewhere. There is quite likely to be an impact on the existing supply chains the way people do business and an increase in administrative burden for both revenue and for business because there's going to be a lot more information provided. In the context of Ireland, recent budget, we have had the minister set out the roadmap, which is clearly showing, if you like, what Ireland itself expects to have on the table going forward, that the key elements there were a reputation, the regime and rate. And as Mark has indicated, the fact that the rate is being reaffirmed is something that's positive. Businesses don't like dealing with change. They like to have a certainty as to what the position is going forward. The proposed introduction of the knowledge box is likely to be key in relation to the offering that's going forward. Risks and concerns. There's a concern that the outcome of BEPS project may go further than addressing the issue of profit shifting based on erosion. As was mentioned earlier, if one looks at some of the other comments that have been made, that the project is very often one gets the impression that the project is not so much about addressing these particular issues as potentially changing where people end up having to pay tax. So there's an acknowledgement in the papers that the digital economy, IP can be responsible for mostly economic value created. And the whole issue as to how IP will be taxed going forward is an open issue, so it's a risk and concern for businesses. As has been flagged earlier, the whole issue as to how return and capital should be taxed and how it should be reflected in international operations is an issue that is still open and gives rise to risks and concerns. And there's going to be a major increase in the administrative burden to be carried out by existing entities in relation to information to be provided. But all of this is in the context of, if you like, the same profit pool. So we have all these additional costs arising. It's the same profit pool. So in relation to the comment made earlier as to whether treasures will be net beneficiaries under this, clearly there's going to be some losers in the context of everything. So that's just to lead into our conversation. Thank you.