 Firstly, let me share with you my favorite description of the BEPS process. I won't read it out to you, you can see it on the screen. I draw your attention to two sentences in particular. One that says holding companies, private agreements, patent monopolies, offices registered in small and tolerant countries. And then the last sentence reads, nobody very much likes a successful entrepreneur. I think that's also true today. Now there are two interesting things about this quotation. One is the, which, which is a quote from somebody who is addressing an organization that's engaged in BEPS. One interesting thing is the identity of the redacted name, and the third is the date. Although you can probably see from the references to the common market that it's likely out of date. So the organization referred to as something called the Intel organization. And the quote comes from page 30 of a science fiction novel called Andromeda Breakthrough by Fred Hoyle and John Elliott, published in 1962, long before the real Intel was ever formed. I think this merely, this shows to me two things. First of all, Fred Hoyle, who is a very well-known and distinguished astronomer in the UK, and no mean writer of science fiction, also had a great appreciation of international tax planning opportunities. But as a science fiction fan, you can imagine my delight when, on my way to the first meeting of the expert group on the digital economy in Brussels, when I found, first, a bus stop, and secondly, a bus both headed for Andromeda. But who is this really about? So part of our briefing in the expert group involved this wonderful picture from an economist article called The Relents of GAFA, again an imaginary location containing Google Earth, Fortress, Facebook, Appalachia, and Amazonia. And in all of the discussions on the digital economy and the tax contribution of the digital economy, we see to keep coming back to a very small number of companies who are very widely represented throughout the world. But what is it that distinguishes the digital economy? I think it's four things. It's disappearing borders in four different dimensions. Firstly, geographic borders are much less relevant. And secondly, we're seeing an erosion of the boundaries between sectors of the economy, between media and technology and various other areas. And we're seeing interchangeability between digital and analog versions of things, so a book and an e-book, for example. And very interestingly, we're seeing an erosion of the boundary between classical production and classical consumption, so the ability to have a globally based car boot sale through some of the sharing websites. And of course lastly, erosion of the boundaries between goods and services. And this erosion of boundaries makes it necessary to consider whether the international tax rules are fit for purpose. And we usually have this discussion in the context of the direct tax rules. And in evaluating whether they're fit for purpose or not, we need to consider what is their effect. Well, their effect is, and has been for the guts of the last century, that if you have sales into a territory, you do not report corporate income in that territory, and therefore you do not pay direct tax in that territory. Secondly, there is no corporate taxation without a permanent establishment, which does not include either a warehouse or a website. And thirdly, it seems to be readily possible to report and disclose high levels of profits in tax havens or in entities that are not subject to tax. And I think it's probably this last feature of the international tax system currently that makes it particularly important to start addressing that issue. And that arises because of a mismatch between national tax systems. So that national tax systems throughout the world are like pieces of a jigsaw, but they're not joined up to make an overall coherent picture. And in the spaces between the jigsaw pieces, there are many opportunities to lose profits, to report profits in areas where the activities are not taking place. The OECD response to this via the BEPS process is a painstaking and careful attempt to join up those jigsaw pieces in a coherent manner so that everybody pays tax somewhere, which I think is a very good initial principle to operate on. However, the current juncture that we're at really gives us an opportunity to think more carefully and more strategically, perhaps, about fundamental concepts of tax thresholds and allocation of tax base between countries, and particularly in the context of multi-nationally operating entities. And a good framework that we might consider doing this is the framework provided by the Merlis Review in the UK, where really there are four sets of players within a multinational enterprise operating in all the countries in which it operates. Firstly, and very importantly, there is the jurisdiction of the parent and how it exercises its jurisdiction to tax over the operations of the multinationals. And secondly, there's what Merlis calls source, but really it's the country where the operations take place. So where the factories are, where the shared services are, where the R&D take place. Thirdly, there are the destination countries into which the sales are made. And lastly, but very importantly in an international context, there are the financing countries. So these are the places providing the debt and the equity finance. And obviously for a multinational, both equity and debt will be sourced in very many different jurisdictions. And until we create an international tax system or a series of national tax systems where the relationship between these four pieces are coherent, it seems to me that we are going to continue to flounder. If we were designing an international tax system, Abenicio, we would probably focus on some first principles. And of course, in these discussions, the economists are always to the fore. So we would undoubtedly have as our first port of call economic efficiency, a tax system to minimize the effect on behavior. And related to that, a tax system to minimize the distortion of competition. We would need to give some consideration to distribution of equity. I think that's particularly difficult in an international corporate tax context. And I wouldn't myself hold out any prospect that would go more than seeking to achieve the consent of the producing and the consuming countries in that system. And last but certainly not least, we would want efficient compliance and administration so it would be inexpensive to comply with the tax system. Taxes would be administered fairly and transparently and we would have a tax system that was stable over time. Now, that would be a wonderful starting point if we were designing a tax system for the planet. But we're not. We're designing the interaction of many differing national tax systems. And as of right now, I don't see any country that is prepared to cede a significant amount of sovereignty. And in particular, that is prepared to say I won't put the position of my citizens and my companies first in negotiating through this process. So I hope the BEPS process will be successful. In the longer term, I suppose the policy options that are up for consideration are how robust are the transfer pricing rules. And in particular, will the current BEPS process make them robust and up to seal up those gaps between the different jigsaw pieces? The second longer term policy option for consideration is what is an appropriate tax base and allocation method as between countries. Now, I see this debate as a big battle between the gods, okay? In one corner, we have the God of Arms Length Pricing, where profit is allocated according to functions performed, taking account of assets used and risks borne. Too often, as that is currently applied, the result bears no relationship to economic reality and results in artificial manipulation of assets and risks. We had a number of good examples of that from sorely at the earlier presentation. So that needs to be fixed in the BEPS process and it needs to be fixed fairly quickly. However, in another corner, we have the God of Formula Reapportionment, much beloved of the commission. This will allocate profits by reference to a formula such as sales, payroll, and fixed assets. But that result is going to reallocate the corporate income tax base from producing countries to consuming countries. And I see it as sucking the tax base into the consuming countries, in my view, an inappropriate way. It can also result in hugely irrational business decisions. Because for example, in taking a business decision on whether or not to outsource, you would need to factor in that outsourcing could have an enormous impact on your tax burden internationally. So in looking at the longer term and in looking at the policy options that are available, I think it's very important to bear in mind, well, okay, we have among the academic community the God of Economic Neutrality. Now, nobody is doing that at the moment, but it would allocate corporate cash flow based on the destination of sales. And it would completely shift the corporate income tax base to the location of consumption. So that both that and CT would be allocated based exclusively on sales. What's important here is that we have a pie of taxes, not a slice of taxes. So corporate tax has taken the bulk of the debate so far. We need to bear in mind that tax is collected in three ways in this respect, corporate tax, VAT, and income tax, or capital gains tax. And so, for example, those base eroding companies generally have their shares owned by people or organizations or other entities. And they are subject to income tax and capital gains tax when they sell the shares. On VAT, we were fortunate in the EU expert group to have already a firm foundation within the VAT system and to have a well-developed series of policy options. I think it's generally recognized internationally that the ideal outcome on VAT will be neutrality and an operation of the destination principles for the supply of all goods and services. And on 1st of January next, we're going to take a brave step in that direction within the EU when we will have a one stop shop for registration and remittance. So essentially, one member state will collect all of the tax and will divide that at the rates in the country of destination and will divide that out to the other member states. Within the expert group, we were very much of the opinion that this is only a first step and that we need to build incrementally beyond the electronically supplied services that will come in on 1st of January to a full destination-based VAT system so that the entire VAT revenue would accrue to the destination location. In VAT, as in most taxes, administration is the key. So it's absolutely essential in moving forward in VAT reform that we make registration, reporting, payment, compliance, and indeed audit work efficiently. And there are huge opportunities to use technology to do that. And I think our own raw system is a beacon of light in a dark world there. Secondly, once we move this concept outside the EU, we will need to be prepared to extend tax treaty provisions to cover indirect taxes. And we will need to promote common global standards, both within the OECD and outside the OECD. And most importantly, we will need to promote effective and joined up tax administration everywhere. We are facing probably some of the most fundamental changes in the international tax system in many decades. It seems to me that there are a number of conditions for the delivery of effective solutions. But I think the choices are about political economy, rather than merely economics. We have to make choices regarding the balance between source and residents' countries. We have to make choices about the balance between how the tax is collected in reference to production and consumption of resources that are increasingly scarce. And we have to draw a balance between powerful corporations and policy makers with divergent objectives. So that task is yet before us. Thank you.