 Cyffredinol yn ymgyrch am gael arall i'r tîm, sy'n gweithio'r cyffredinol o'r cyffredinol Cymreithio Cymreithol ar y gŵr. Felly, mae'r cyffredinol yn gweithio'r refform USA oedol, mae'r cyffredinol wedi gweithio'r cyffredinol yn ymgyrch, os yw gwaith ymdweithio'r refforddau i gyd-gredinol i gyd-gredinol gyrsio eu cyffredinol i gyd-gredinol i'r cyffredinol. Rhaid oumbledwch eich gweithio ychydig yn cael ei wneud ychydig i gydag yr aes ac mae'n gweithio eich cwynhau i dda i'r cych o'r amilyniadau'r gweithio. Rhaid oumbledwch eich gweithio eu gweithio, a rhaid oedd eu gwasanaeth cael ei g Uno oedd ddoch chi'n edrych yn eu progrin herald – y cyd-dur yn ysdau. Rwy'n ei wneud i ddwy i'r Eirys ar y cerddmwyach. Byddai yn cyfyrdd yr ysgolffan ar y cerddwydau ar y cyfrifatwyd o unigon Cymru a gyfan odd mae'n ddiweddar o'i cyfrifatwyr o'r cyfrifatwyr gynhyrchildaeth sy'n gafd00 o'i gwybod fel tufynionUND mae'n gwybod fel tufynion ac mae'n gwirionedd ymgyrchu i'r dyfodol y ddechreuwch arnynni'n eu fan yw'r cyfrifatwyr e'r cyfrifatwyr cyfrifatwyr oedden nhw'r cyfrifatwyr eich bobl ysgrifennid o'r gwirionedd ydyn nhw i'r byd mae'r ystyried yma sydd wedi'u gwneud am y tyfu ac yw'r ysgolwyddon. Mae'r ystyried yma sydd wedi'u gwneud o ymddi'w gwneud ymddi'u byddai. Fod ydych chi'n gwybod ar gyfer y riliadau ar y gondoli'r cymryd yw'r ysgolwyddon, mae'n ddigon i'r ffordd i'r ffordd yw'r hynny yw'r cyfrifio'n ffordd gyda'r cyffredinol, ac mae'r byd o'r perfiddech chi'n ddefnyddio'r dweud. Rwy'n credu'r credu. Mae mae'n enghreifftio y mydraig o ddiwedd mor hyn, ac mae rhai os erioed o'u gwybod yma ym wythch yn e-commerce. Felly y tax-code yn y cyfnod digidol. Roedd yn y cyfnod rallon yr e-commerce, roedd y gallu'r cyfnod yma. Mae'r gwahod mewn tax-code ar hyn o'r nôr bod y pirmennu amser. gyda gael y cyfosib am gyfosib dros gennym, a lle mae'n gael y ffaptoriaeth, mae'n gael i chi'n gael gael. Mae'n ddiwethaf o'r bwysig ymrhyw gynhyrch yn y cyfosib, wedi gael. Dwi'n gael, mae'n ddiwethaf o'r rhaglen digidol, a dych chi'n ddiwethaf o'r rhan ffodol. Mae'n ddigidol oherwydd y cyfosib yn ymgyrch yn y cyfosib. Mae'n ddigidol yn ddigidol i chi.Clond.a'r gre Arts is a vision of how to do this the U.S has a vision of how to do this Germany has a vision, many others have a vision of what this should look like Australia. Minister Downey I'll go back to you. I wanna be blunt a lot of people are accusing Ireland of dragging its feet and not wanting to be involved in this discussion. What is the role of Ireland in defining what a digital permanent establishment looks like? Yr hyn yn ymgyrch, ond ydy'n cael ei ddweud yn gweithio'n ymlaen nhw y Un i'r uneddau o'r ddweud o'r chynlluniaethau a'r ddweud o'r ddweud yn ymlaen nhw. Ond ond ar gyfer mae'n ddweud efallai fod yn ymlaen nhw, bod ymarfer yn gallu'n ddweud o'r ddweud ymlaen nhw yn ymlaen nhw, sy'n ddweud i'r ddweud, ond ond ymlaen nhw yn ymlaen nhw. Rwy'n ymlaen nhw'n eu cymdeithio ar y byd, ac ryddech chi, yn rydyn ni'n ei ad issuesio ar y cyfarwydd ddigonol, sy'n rydyn ni'n ddidd спynnyddio'n cymdr. Rydyn ni wedi bod yn gyflawni i'r ddawn da�nau gwahagnyd eich cyfnod gyda'r increase rwyf ar dweud awgfodol Cymru. If you are exporting economy, and if you a service exporting economy, that poses a gigantic challenge for us. And I have to reserve my rights, of which I have done, to say I am sorry. I am sorry if a change like that will set a precedent that if you're an exporting economy will be a real challenge for us. The other grave concern that we had is that we believe a change like this, the safest place to do us is in Engel's organisation. Because if we don't have the engagement of the US, if we don't have the engagement of Japan, if we don't have the engagement of China, I believe we run a real risk of a tax issue becoming a trade issue. And I don't need to tell this audience of the current trade challenges that we have. So what are we thinking of moving forward to? Firstly, we acknowledge this system needs to evolve and needs to change. Secondly, we believe that this should be treated in a way that is similar to how we organise corporate tax policy at the moment as I've come out of the BEPS process. And thirdly, what we're looking for is balance in recognising that value creation is genuine and does happen within companies and that the tax incidents should recognise that. It's really complicated, it's very technical, but if you look at the progress that was made in BEPS, many said it wouldn't happen. And it has happened and we all have our part to play in that process now. And you sort of alluded to this, is there an approach that you're leaning towards and that you think makes the most sense so far? It sounds like you're not in favour of the UK approach of taxing based on where users or in-face users are. I'd prefer to say though at this point I think there is. So I think the key issue that we have not yet teased out in the debate is there is an assumption that there is a digital economy here and the rest of the economy over here. Whereas in fact what we have had is an entire economy that has become digitised. More and more. And I think we still have to figure that out. So that is why the principle that we have for other elements of corporate taxation we will hold in relation to digital taxation which is you need to be cognisant of where value is created. And my own view is we haven't made enough progress in that yet. And I think where you will see that happen is in the inclusive format work that is now underway led by Pascal Santaman in the OECD. And we'll play our part in that. Let me just ask him one more question so the hot topic for him. Given this is the first time in my career I've ever been described as a rock star of anything. I do feel I should play my part. Enjoy it while it lasts. Because I don't expect that description to last for long. I mean as you well know the EU proposal for that 3% digital tax failed in the last few weeks. There have been calls as I'm sure. Those are sales tax. This is what he says. Well what I'm trying to go with this is what your stance is on taking away the unanimity around tax issues in the EU. There are calls that we wouldn't need every country to sign on to a new tax proposal in the European Union. That seems directed somewhat at you and the Nordic countries. I think it's very interesting that when this policy is put on the table the assumption is that the people who will be most concerned about it are countries like my own. And the countries who will be most vocal about it are finance ministers like me. Only one of those assumptions is correct. You're right. In the kind of debate that's on the way and has been on the way. I have been careful in trying to protect what I believe our national interest is. And I do this as a politician who's completely committed to the European project. But what is also the case is that there are many many many other countries within the European Union. Small and medium size than indeed some quite big. Who would have grave concern verging on complete opposition to allowing their ability to set their rates are based be removed from them. Where we have made incredible progress on and I think again this is still has to be called out is the work that has happened on templates and standards. While less clear at times than what's your race is having an indelible effect on what our corporate tax landscape is going to be. And I believe that's underestimated in some of the debate that's on the way though of course not here Heather. So if I'm hearing you correctly you're not in favour of getting rid of unanimity and you think you're not the only one who feels that way. Yes to both. Would you like to jump in? No I don't want to talk about the governance of the EU. I mean it's difficult enough. Now on the sales tax issue what was the original? Well not the original but the French promoted the zero directive that should have started on the 1st of January this year which it didn't. And that was a 3% missed sales tax. It was a 3% on turnover. It was a 3% on your invoice. Now why 3%? Well because it was assumed that 3% on the invoices has something to do with some kind of proxy with the type of profits you could get. Because normally if you tax the profit at 25 or whatever it is when 12.5 in your case. But the question is that it bears a certain relationship has to do with an imputed benefit or profit from a certain size of your invoice. Ok now this is what the British did. They went out there and they got information from third parties. That means everybody who did business with this company and they say well they all tell me they spent so much and therefore they gave you so much money and we're going to assume that out of that money you made so much. So it's the imputation of the imputation of the imputation and that becomes quite you know after a while. First of all it's easy to avoid and second it's relatively it becomes very theoretical and sometimes it may become unfair. But there is a political imperative here and that is people after the crisis. You still have very high levels of unemployment in a bunch of countries and you have two issues. One is the man on the street has to pay the taxes whatever it is 12.5% or 25% or 30% rich people put the money in a tax haven therefore didn't pay taxes. Companies small and medium sized companies pay taxes. They are constrained by the borders and then large companies did not pay taxes. The difference between the two cases the first one was illegal the second one was legal because we built these rules to avoid double taxation. We created the perfect double non taxation and therefore we now have to get back and rewrite the rules. This is a complexity and this is why everybody is trying now. What everybody has agreed whether it is France or whether it is the UK or Italy or Spain whatever is that the moment there is an OECD deal on the table then they will start a sunset. And they will roll out their temporary measures and they will go with the OECD solution. So this is why it's interesting this is why it's important and this way a lot of people are saying we will move in that direction when there is if and when there is an OECD. How long do you think it will take to get an OECD? Oh we have a very clear timeline a very clear mandate 2019 we are going to deliver a relatively detailed or relatively let's say a set of complete set of a good compass a good signalling system and then we will deliver the final report and start implementation in 2020. But that is the way the G20 mandated us. We are not lagging behind this is not late. I say this is too important to be urgent so don't trip over yourselves in order not to do it now. But if there is a political imperative then of course we respect it but let's make sure that everybody is ready to move forward when there is a deal on the table. And here I like to recognize the presence of the Premier Bermuda who is a country he's gone the extra mile a lot of political courage precisely in order to align his country to these international best practices. What I want to say is that we can already act. You said it's legal. A lot of this stuff is legal but a lot is not legal if you have a really close look. Look at apple, look at Nike where the European Commission is now having a look if their system with Bermuda and Netherlands and other branches is illegal state aid or not. So I think it's very easy to say we have to wait. We have to wait but we also can act already now and my call is aside from that for more solidarity especially in the European Union. We're like brothers here and still we are losing billions. We are losing billions of taxes that is lacking for better schools for safer roads for better education. And when we talk about billions and millions it's like flowing around but it's not you know the human side is really important for the people out there to understand. I think we have sort of three areas. What we've been discussing a moment ago is well we recognize there are harmful processes but they're legal and we need to develop principles. Some of them pose challenges. The point you raise digital economy there are very different points of attachment and it gets more immaterial the longer the process goes. If you look at a cell phone it starts with a gold mine somewhere and then you have an element in Silicon Valley and then ultimately you have somebody who buys it. And the question can be it can be debate where would you then tax to what extent of the end up process. The other point would be the other extreme that was our main interest is the clearly illegal. We've been seen we've been seeing enough of it. I mean Panama Papers is all over the. It's all about illegal practices first of all would be good if we can get get our hands on them. And then in between there are forms which are maybe not thoroughly illegal yet but they're very clear they have only one aim and that's circumvention and that's where you are with with your harmful tax initiatives. Yeah if I would just agree with a point that Bastion made there I mean you will have expected me to hear me make some of the points that I made earlier on. But as an elected politician the point that Bastion has touched on there about the need for a social contract in relation to taxation I think is an essential point. And it is. But in addition to that the two OK I got to jump in there. Some would argue that Ireland's a free rider. You're not contributing up taxation Germany and others are doing that for you and providing defense and other capabilities in the EU. And how do you sort of say you're doing a fair job. Yeah so what I would do is I would point to what we have done over the last number of years and to say the issues that have been a cause of debate and been a cause of concern. They were they were recognized but what I think needs equal recognition is all of the actions that have been taken by myself and my predecessor to respond back to them while also asserting our rights which we have as a country to look at how we can be competitive. So we touched on there for example in relation to an arrangement that was associated with Malta Ireland when we now have the changes in place to make sure that can't happen. I've touched on many of the treaty changes that we have implemented through our finance bills and in relation to Apple and let me deal with that head on because it's been touched on by a number of participants here. So within the European Union we disagree with the assessment that the European Commission made of it but we have played by the rules in relation to us. We were asked to put in place a process to collect 14 billion euro. We have done that. All that money has been collected in cooperation with Apple and we have done it. And the key case that we will be putting forward here is much of the charges that have been levied at us are due to the fact that there was a mismatch between our tax code and the international tax environment. And a huge amount of this has now been addressed by the change that has happened in the American tax code in particular regarding the patriation of earnings to America. So, yes, Sarah, to take your point, what are we doing in relation to the social contract both for our citizens and within Europe. It is the changes that we have made and I'm committed to continuing to do that. Let's do one more question maybe on the US impact and then we'll open it up to the floor if anybody has questions in the room and I bet they will. So, the big concern a year ago when the United States lowered its corporate tax was that we were going to start a race to the bottom where everyone was going to start slashing their taxes and we were just going to get lower and lower and lower. We're a year on, we haven't really seen that yet but we have seen some proposals. Mark, is that still a concern of yours that we might see a race to the bottom in taxation, corporate taxation? Well, my angle to this is that, you know, small countries are vulnerable. So, if we want to squeeze small countries into siding with the general attitudes that for instance a body like the OECD is developing, they will actually participate. That's what we've been seeing but the US of course is the real free rider. I mean, it has to see it that way. Not in an equal way, there are some states that are more a free rider, more of a haven if you want but they are the real problem. But, you know, a lot of smaller countries teaming up to tell a bigger one we've had it now, we want you to join. These are the rules, that's a possibility. I think that's my experience in international work that you can actually also tell a big guy to, yeah. You want to jump in here? Yeah, about Bastian's point about the millions and the billions. We have, I mean, we've already counted, we count, the countries receive the money. More than 95 billion euros, which is 110 billion US dollars. Simply from taxpayers who are now convinced that their name is going to end up in the taxman's desk if they don't come and declare it first. And they have come in and said, oh Mr Pascaldon, can we, in the hypothetical case that a hypothetical, you know, taxpayer would have, you know, my secretary didn't send a copy to you. My God, the report was missed, you know. I should make it clear that I have not had this discussion with anybody. Or would I get out for any near of Mr Pascaldon. What can we do and say? Well, I would invite you to, I don't know, change your uniform, one for a stripe, one like that, you know, something like that. But basically, 95 billion have, quote unquote, voluntarily come in and paid. Now this is not the assets. These are the taxes. It represents 10, 15 times more assets that are deposited in there. And now they're coming forward because they are convinced that there's nowhere to hide. So this is happening. Now, we've reviewed 240 preferential tax regimes. Half of them have been amended or abolished. Real progress. Really important. Countries have started to exchange information on 16,000 tax rulings. The tax rulings are now mandatory to publish. So the question of transparency has been modified, has been increased exponentially. And we haven't finished yet. And the tax on digital is one remaining issue. But the progress is absolutely, you know, it's undeniable. I'll quote a classic called Mr Putin, Vladimir Putin, who said when we went to the G20 in St. Petersburg, he said, this is the greatest revolution on the international tax regime in 100 years. Because that's where we launched it in the St. Petersburg G20. We're going to cut you off so we can get some audience time and then we'll circle back. And maybe you can make some other points. Any questions from the audience? Jump in. Yes. A couple of weeks ago, the Spanish government approved two taxes. The digital tax, so-called Google tax. And the so-called Tobin tax on financial operations. What I'm asking is, apparently Spain has decided not to wait. And I would like to ask you if this changed the landscape or the time in the agenda. And if it is a good idea, implement these new taxes alone. Great, thank you. So I made the case earlier on for the ability to set your tax rates being an element of your national economic sovereignty. So therefore it's only appropriate to recognise Nadia, my colleague in Ecofin and Eurogroup, for the decision that she has made in relation to the particular rate that you've referred to there. Do I think it will slow down the kind of debate or momentum that's underway within a European or international context? No, I don't. And of course it is the right of the Spanish government to determine how they want to set a rate or how they want to set a base. And just to refer back to the point that Heather made there in relation to a race to the bottom. Very briefly, I will not be reducing our rate. I've absolutely no plans to do it at all and I will not be part of such a trend. And secondly, my judgement is that you will see a movement down in top line rates. But I don't believe it will be of the magnitude as many are currently indicating. That's great. Did you have your hand up? I'm not a member of the media, I appreciate the opportunity to ask a question. And this would be to you Minister of Finance. Clearly a lot of the concern for people in jurisdictions like mine are the new EU economic substance rules which are now being adopted by the OECD. In your view and some of the statements of what you made is that you felt that these type of global tax changes should be better done through the OECD as opposed to the European Union. I guess it's a hypothetical question not asking to speak for some of your colleagues. But why is it that you think that so many of your other colleagues do not take that same view and do not wish to work through the international system they're trying to unilaterally force it through on an unbalanced way for the EU? Okay, so the most difficult kind of questions to answer are ones that are hypothetical. And at least you were good enough to acknowledge that it is a hypothetical one. And I'm certainly not in any position obviously to speak on behalf of some of my colleagues. I think the reason why there is the kind of momentum that you've just described there is a concern on behalf of some colleagues that it might be very, very, very difficult to make any progress at all on that area internationally. And there's more of an aptitude for trying to do that on a regional level than a global level. And I think that is influencing some of the debate you're seeing at the moment. Do you want to... They all want to work with us Prime Minister. I don't think the point is that they would say I'd rather work outside of the OECD. No, the question is the OECD has a certain process where it takes time to do multilateral issues. Unilateral takes one leader, one congress and you've got attacks. Well, sometimes it's very difficult to get one leader, one congress agree or whatever. But the point here is we understand the political imperative. We understand why Bruno Le Maire or why the Italian Giovanni Tria or why Nadia Colvinio are saying let's tax digital. Because we need to tax the digital. The only question is we haven't taxed the digital for a long, long time and therefore perhaps putting it together, doing it very carefully, but they appreciate having a broad-based agreement. Why? Because if you do not have, this is like the automatic exchange of information, which you have been so important in, you know, practicing in Bermuda, but also leading the church. If you do not have everybody in the game, then you just go to the country next door. This is like corruption, Mr Pete. He is the big anti-corruption czar of the Lord and whatever it is. But the question is, and if you do not have everybody playing by the same rules now, it does not necessarily have to be the same tax rates, but certainly the rules have to be the same. Otherwise you can go, but Google tax please, the Google tax, any country as long as they are ready as Italy and Spain have been, to say, OK, I'll remove it the moment there's an OECD deal. And last but not least, the Tobin tax is a very old tax. Many countries have practiced it and they all say it's temporary and nothing more permanent than a temporary tax. So beware. Maybe it's not a better idea if some go ahead, you know, give a start and show that it's practical and then follow the OECD when it comes. I think it's a better sign than everyone holding back and saying, oh, there's no international regulation there. What should you learn about, you know, trial and error? Yes. I think though we should, from the point of view of Europe, as a part of the world that is a net exporter to the rest of the world, I think we should take great care about establishing tax policy in a way that's perceived to be targeting particular companies. Europe is about designing tax policies for an economy or for part of an economy. And I think this is something that we need to be aware of in the global debate. All right, one more question. The back was first hand. Hello, it was Stephen Carlin from 24. I spoke to Britain and America a couple of hours ago and I asked him, did he expect there would be an EU agreement? He told me that he thought that he would be able to convince the four EU countries that haven't signed up to the digital tax. So consider yourself warned minister. He said that himself with his German counterparts will be doing everything they can to convince you. Will they be able to do it by the end of March, as Bruno Le Maire says? Okay, well, I had the opportunity to meet my good colleague Bruno earlier on today. And both of us look forward to meeting maybe in Dublin or in Paris kind of in the coming weeks. Bruno's already offered to buy me a beer in relation to all of this, as you may well know. But I think it is fair to say, and this won't surprise Bruno, that the concerns that we have in relation to this, you know, are of a very, very principled level. What does it mean for future tax policy for exporting countries if you shift taxation to where consumption happens? And that transcends even the debate that we're having about the digital economy. And there are quite a few countries within the European Union that have that concern. So we will continue to be active and constructive in the debates. But I think there are economy-wide implications of that approach that will continue to become apparent in the debate that's going to unfold on us. I think that's all the time that we have. Thank you all for your insights and thanks for the great questions. And please, everybody's always wanted to know about the digital tax problem that's in our website. And this is the document we released last March. March a year ago. This is the one we just delivered to the G20 heads in Argentina. And there's a lot of progress. Here it was all about why we don't agree on anything. And this one is a convergence story. And this is within the same beer. Not bad. Thank you.