 Let's start. I think it's good to be generous on that second morning and let people slowly ease into work mode. So please allow people to come in and find their places as we start. My name is Arvin Gaddel. I am the director of something called the UNDP Global Policy Center for Governance. I'm going to say a little bit more on that in a moment. But first I'd like to thank UNIWIDER for pulling together this group because it really for me is a sense of Christmas I was telling Peter Chowler here yesterday because it is truly special what UNIWIDER manages to do with its convening power. We know the power of bringing academics, researchers, practitioners and policymakers together in the same room. And to me you are more than that. I actually think of you in terms that are perhaps more important. For me you're plumbers, you're architects, you are leaders that the world didn't truly understand they needed. And we'll get back to that in a moment for the session. Because I do think that underlying so many of our problems in the world today is this issue of financial integrity. And you as a group have the power and the tools to solve some of those problems. But I also have to say that it's a true luxury as you all know to travel far to be in a conference together in this day and age. And it's a luxury you shouldn't take for granted. I think it means that we have an obligation to use that luxury. What that means is testing our comfort zones, making sure we test each other's hypotheses, but not least test your own thinking. What I saw yesterday was a lot of brilliant conversation. But I dare you to test each other more. Because that is the only way that we can find these solutions and really you have an obligation to. You have an obligation to test each other's hypotheses and do this in this conference. Interrupt, be part of the conversation. Don't just repeat and review. Be active. So with those words, it was a bit harsh maybe at the beginning in the morning, but I thought it was important for me to say that because I feel like there's so much potential here that needs to be used. Now for this morning session, we're talking about tax evasion and in a way it's a perfect framework for the rest of the day. And you will see as we start the conversation with our esteemed panelists that the range of issues that we can cover are enormous and we'll try to cover some of them, but the underlying theme is in many ways the same. And let me just take you then, if you allow me, for a bit of a helicopter ride or let's call it a space rocket ride into the stratosphere and look at the planet for a moment. Because what are we seeing? At the moment we are at a historical intersection in human development. I represent the United Nations Development Program and we produce every year something called the Human Development Index. The Human Development Index in an index that measures human development according to three different functions. For the first time in 30 years, we have now two consecutive years of regression on the Human Development Index. Of course that may not be surprising, however, in disappointing, but what it clearly is, is a wake-up call. But perhaps even more than that, it is an intellectual challenge, apart from of course the human cost this has. For us as plumbers and architects and leaders and managers in this, let's call it hidden field, of designing a new world, a new way of functioning in our international financial system, we need to think entirely differently because progress is not automatic. That is for me the most important insight from that finding for the Human Development Report, is that while we for 30 years have been used to relentless progress, slower times, sometimes setbacks, we now have systematic regression. Now, what does that mean for us in this group? And quickly, let me throw at you a thesis that will attempt to bind together the initial tax evasion and financial integrity. There comes Peter, who I just referenced. My current concern is that next year is the international super year for democracy. Never before in human history have so many people prepared to go to the polls, as for 2024. Close to 2.5 billion people will put their vote in a ballot box next year in more than 70 countries around the world. This can be an unparalleled party for democracy, a show of force for an idea that is 2,500 years old, or it could be the complete collapse of that idea. 2024 is that breaking point potentially, where as the Secretary General talks or calls it, either it's breakthrough or breakdown. And our, you know, serving of the world from our rocket ship, UNDP, tells us there are a few trends that we need to understand to understand the importance of 2024. One is uncertainty, and the fact that we as a human race are facing an uncertainty complex we haven't ever before. Uncertainty is not new for humankind. We've always dealt with it, for millennias. But the layers of uncertainty that we are facing now create such a complex decision environment that it's really hard for decision makers like yourselves, but also for individuals in our societies to make up their minds about what is the right way forward. We know, for example, that six out of seven people on the planet feels insecure about their future. Think about that for a moment. Six out of seven people feel insecure about their future. What does that do to people? We're not one or two or three, but six out of seven feel insecure. How does that change the decision matrix? Yesterday in the opening session we talked a little bit, our keynote speaker talked a little bit about behavioral economics. Well, I have, my claim is that we have no idea what's hitting us, because this uncertainty complex is so ingrained in our societies now and in so many ways affects human behavior in ways that we wouldn't have expected before. That's one. The other is of course trust, and many of you are in the business of trust. Vertical trust, but also horizontal trust. We ask people questions around the world about to what extent they trust each other. Do you trust regular people? Last year we reached a record low. Only 30% of the population of the world trusts other people. 30%. What does that mean? What does that mean? And on the statistics, if you look at how businesses are trusted versus governments, we see a very clear trend. Businesses are regularly trusted at a higher level than governments. We know from this something called the Edelman trust barometer that about 51% of the population of the world trusts the government, 51%. While about 62 or 63% trust the private sector, generally, as sort of a general statement. Again, what does that mean? So if you put in certainly complex this layering of uncertainty, the change in the way that people see the world, together with this trust issue, and I could of course also talk about the issue of polarization, which will be a very consistent data across the world, how uncertainty drives polarization and the other way around, we are confronted with a complex problem of enormous proportions which cannot be solved only by governance experts or economic or financial experts. So what do we do with this? Well, my claim is that we need to forge an alliance between governance people and PFM and economics and finance people. Because as a development economist myself, I have since this for many years, how these are two realms or communities of practitioners that really actually interact and meet. That those people who work on human rights and legal processes and democratic processes don't actually understand PFM or tax collection or all of these financial issues. And those who work on technical reform or economic structure issues, they don't understand really, and I'm sorry, this may feel a bit offensive, but it's really a trend that they do not understand how politics works. So how do we bridge these things? And the final thing before I invite the panel up on the stage, we know that one of the most efficient drivers for distrust, vertical distrust, so distrust between individuals and their institutions is corruption or is a proven corruption or the sense that there is something bad going on, right? Something that is out of my control as an individual and people are getting rich and I have no control, I cannot stop it and they're stealing from me. The moment that is the prevailing sense in society, we know that vertical trust is very bad in bad health. And again, then what is the most important driver for that mechanism and of course that is tax evasion. So as we try to solve this plural, what do you call it, poly crisis of nature, climate, inequality and cost of living, we need governance responses that are strong and determinant, but at the time when no one trusts their government. So in solving the climate crisis, nature crisis, we don't really have the tools that we need. But in order to regain that trust, you need to handle the dirty money. If you cannot handle the dirty money, and this is the thesis and the logic, you cannot solve any of the other problems, any of the other crises. Because dirty money is more than a 4.5 billion or a trillion US dollars that the tax justice network expects us to lose in the next decade. It's also about cohesion and horizontal trust in our societies and our ability to find solutions together. So with those words, I'm not sure if Finn and Kunal expected me to talk that long, but you shouldn't give Arvin the floor without expecting him to talk. I have the pleasure to invite some really, really excellent minds up on stage to discuss tax evasion with us to set the stage for the rest of the day. Gerard Reil, who is the director of the International Consortium of Investigative Journalists. Alex Cobham, chief executive of the Tax Justice Network. Toreil and Pedersen, head of section for Governance and Transparency at NORAD. And Pierre Bachas at Essex Business School and from the EU Tax Observatory. Can you come on stage please and we can start the conversation. So let's start with you Toreil. Can you perhaps reflect a little bit for us on what role tax evasion plays in Norwegian engagement on domestic resource mobilisation? And also we've heard you say this before that you want to put humans at the centre of tax. Maybe reflect a little bit on what that means for you. Thank you. I'll get to the last point, but I think that builds well on your introduction by putting people at the centre of our discussion. But yeah, just to talk a little bit about where we are in the terms of Norwegian development assistance to tax evasion and DRM. I just want to step back a little bit. So we've had an evolution from quite a narrow focus on capacity of tax administrations and then evolved to a bit of a broader policy and capacity to where we have been now over the last few years where we really identified two goals for all supports to DRM under the Tax for Development programme. Everything that we support should, one, have an impact on domestic resource mobilisation at the country level and it should strengthen the social contract or it should at least aim to show how it's contributing to strengthening the social contract at the country level. And with these two goals and this dual focus, of course tax evasion is the primary obstacle to achieving both. Both it drains countries of public resources or potential resources and like you were saying in the introduction, it really erodes the trust that is at the centre of the social contract. So it becomes a vision cycle. And we, as our director said in the opening to this conference, we really try to look at the knowledge base for what should we support really to get the best results out of the limited development aid that we have. And what we, when we look through all of the research that we could find, you know, we're looking for this silver bullet, you know, what is this one thing that we can put our money in, in order to make it, make a change. And of course, as everybody here knows, this silver bullet doesn't exist. This is a systems challenge and we decided to move in the direction more of looking at how can we invest in actors, partners and processes that have a potential to kind of trigger the systems change. Because there's a system change problem, there's obstacles at the country level and there's obstacles in the global north. Our focus is supporting and reducing poverty at country level, reducing inequality at country level. That's a mission that we have at NORAD. And looking at the obstacles that you have at the country level might be lack of capacity, might be lack of political will, might be lack of transparency. But similarly, you have these issues in the global financial architecture that is not allowing, even if there were the perfect, the perfect combination of factors at the country level, you know, you won't be able to actually overcome it just by having action at the country level. So what we do is actually all of the gentlemen here on the panel or represent institutions that, you know, we have assessed as having the potential to kind of nudge us forward in the systems change approach as well as you and your wider, right? Creating that knowledge for understanding where should we be putting the investment. And we have limited resources, like I said, even if the ADAS for tax-related development has doubled or more than doubled since 2015 is still very limited resources and it cannot solve the problems. Problems of capacity, you know, sometimes problems of capacity is just a challenge of numbers. If you have two people to do a 200-person job, the amount of training and capacity development isn't going to solve it. So, you know, and we're going to solve this by aid money. And I think Dan Vanik also mentioned this yesterday in the discussion, you know, each source of funding has a specific purpose and we think that the aid that we're spending in the DRM field should be focused on making the systems change. And that's the most effective way of doing it. And not all of it will work. It's a gamble, right? We're looking at a lot of different strategies and some of it we've already seen, you know, the engagement of civil society has led to a whole new discussion in the tax field on the tax evasion and the transparency discussion. Research is a whole different set of research questions that we have now than we had, you know, 10 years ago. So that's kind of the, that's the gamble that we're doing with the aid money from Norway and the tax field. What it also does is that it allows us to look at solutions for two tax evasions that are outside of the traditional tax field. You know, tax administrations alone are not going to solve tax evasions. Many of the institutions related to corruption, related to the judiciary, related to private sector, some of the solutions are there. So we have to kind of open up the space. And that's something that we're also trying to do by connecting what we're doing on PFM, what we're supporting on anti-corruption and what we're supporting on tax to kind of have a more comprehensive approach. And what we can do is try to make that space to connect partners. We don't have the solution, but we think that the solution is somewhere in our partner landscape. Yeah, it also allows us to operate, to do a lot of work, even in areas where we don't, as the Norwegian government, have an explicit policy. You know, there's a policy that the decision in Norway takes time because that's a process. But what we do have is a commitment to advancing the transparency, to making sure that we're there facilitating the dialogue around the solutions. And yeah, so I think that's on the aid side. And when it comes to the people at the center of tax, a lot of this alludes to that, right? I think we have to kind of change our narrative a bit in terms of identifying, you know, what are the words and triggers and how we talk about tax and tax evasion in a way that makes it relevant to more people. And, I mean, economic models are very pretty on the screen, but it doesn't speak to most people. But there are so many aspects of it that is real and impacts people directly. I mean, my crusade for this started in my teenage activist years when I was in the board of Save the Children. Save the Children has a very service delivery-oriented mandate, but we managed to get them to work on the structural causes to the violation of children's rights, right? Which was the debt burden. It was at that time, and maybe still today, some of the trade facilitation processes and the patents, you know, directly undermining. And similarly here, you know, I think that our biggest advocates against tax evasion and the solutions for tax evasion, I don't think it's in the tax field. I think it's the climate activists that have to show that tax evasion directly undermines the climate financing goal. It's in the health sector practitioners that have to directly show and take up kind of the mantle for this and demonstrate how the direct impact on people through these sectors. And we're going to continue to invest in the cross-sectoral, kind of the foundation for all development, which is these core government functions and the transparency and accountability related to that. But then we have to give the messages to the sectors to kind of, to take it forward. They're speaking to more people than we're speaking to from this room and from this stage. Can I just follow up a little bit, Toriano, because I think it's interesting. It speaks also a little bit about what I'm talking about in the beginning about this bridging. Let's call it this group of people with other professionals and thematic areas or problems to solve. How do you intend to go about that? Or have you started that work to help stimulate that? We've done some, but I think our partners have also done a lot. They're connecting the issues of, let's say, connecting the issues of illicit financial flows to environmental crime, for instance. So we started a collaboration, closer collaboration also with the Ministry of Environment in Norway to kind of link up the investment that we're doing in those fields. A lot more is to be done, of course. But we see a lot of our partners and I think within the journalist field they're also doing a good job at connecting the different spaces. A little bit on the research side, but I think the research definitely needs to step more into this field. So I think our partners are kind of leading the way more than us. We have potential to be better at that. That's a good second to ask you, Gerard. You've been watching this or being playing a part in this increased attention on tax evasion from sort of a different entry point, part of the big gamble, but a different entry point than many perhaps from a journalistic starting point. It's been seven years since the pen and my papers and I just wonder if this is a good time to just sort of take stock of that. How do you, when you look back on that, what was achieved during these leaks and to what extent where they're important, but perhaps more importantly, are they still important? Do they still make a difference you think? Do you think they can help this agenda continue to progress? Or have sort of the potential of leaks driving it, driving progress on this already being taken, used and taken out, so to say? I think Gerard mentioned that this is much more about tax evasion, what's happening here, what we're investigating. It really is about crime, all sorts of crimes like human trafficking, money laundering, but also arms dealing and other things. I mean, what you're seeing here is basically a parallel universe that's being created and I do think that it needs to be tackled in multiple different ways. One way is actually through journalism. I do think that in terms of a journalistic story, it is probably one of the two biggest issues facing the world right now with the environment being one, but I do think offshore financial secrecy is a second big issue and I think that's what's attracting us as journalists to the story. In terms of understanding how it works, the only way you can understand is to have inside information. I mean, for many, many years, I think for 15, 20 years, governments and really good organizations like Tax Justice Network were screaming and saying, this is a major problem, but it really did take Panama Papers, I think, to bring it to light and it shouldn't have been a surprise to people. We even, as journalists, we'd been working at ICIJ on this issue for five years up to that point and we'd brought out many stories, offshore leaks being the first one, then we did Luxembourg leaks, we did the story on HSBC secret accounts, but I think what really captured everyone's imagination was really an enormous good timing with Panama Papers. We had found basically a lot of hypocrisy in there, a lot of the politicians like David Cameron, the British Prime Minister at the time, who when we brought out offshore leaks said, this is terrible, we have to do something about it. I think Tax Justice Network already mentioned that a lot of the problems were caused by former colonies and in fact what this really was was a continuation of that era. But I think, you know, we were lucky in our timing in that one of the major stories that came out was the Prime Minister of Iceland and we brought out the story the day the Icelandic Prime Minister had, you know, Parliament was resumed and I think for the first time ever you saw people getting really angry and I really think this is what drove all the change after that. You know, people surrounded the Parliament building in Iceland, they threw yoghurt and bananas at the building and the moment the Icelandic Prime Minister resigned everything to do with Panama Papers became a big story around the world and that's when you started seeing other protests in the UK and Malta and Pakistan and other places. So I guess the point I'm trying to make to you here is that you need to get people to understand the issue, to really understand the issue before you start having change and I think you can do that through journalism but none of our work would have been relevant if people hadn't already been educated on the issues by other groups. The other lesson that I've taken from this over the years is that story cannot go away if you want to have real change. You cannot just do a one-off Panama Papers and expect everything to happen. There were lots of promises after Panama Papers by the way, laws were supposed to be changed in 70 different countries, you had all this $1.4 billion in tax being recovered, you had all these promises of change and yet what we had to do as journalists was to continue the story but you'll also see that each time we did a new story, we did Paradise Papers next, we focused on multinational tax evasion, we then with Pandora Papers was very much on the enablers. We also have challenges as journalists to make the story relevant every single time. I mean I have seen new data sets that would curl everyone's hair here or in my case turn it even grayer but to be able to do another story on this we have to find new angles and again continue to get the people interested and make them angry, make them angry enough to demand change. You work with national groups of journalists as well so you understand in many ways perhaps better than anyone the appetite for these kinds of stories. Do you see that changing or is that still the same? Is there still this potential for public interest that will turn into the demand for change? We have issues that people outside journalism probably wouldn't understand. Editors they don't want the same story over and over again, you cannot go to them with the same story. It's got to be something new or a new angle for it. I do think there's a huge appetite, I think we're in the middle of another project it'll come out in a couple of weeks time, you'll see that there's an appetite for this work but again the challenge for us is to make sure that it's not the same exact story that there's something new every time and that there's something else for people to be angry about because without that anger you don't get the politicians to take notice and you don't get the advocacy groups to tell us what needs to happen to make things better. I have to ask you can you give us a sneak preview of that story? Look there are challenges that journalism like faces and it's in the context of our whole business The business model that has allowed journalism to operate for the last 50, 100 years is broken and that's the advertising business model. So every media company in the world is suffering right now but journalism was also changing. When I started working 35 years ago getting access to information was almost impossible. You know I would go to a company's house and I would fill out a form I would get the directors of a company and then I would have to go back the next day and fill out another form and get the other companies of those directors where it took an age to get information. Now we have the opposite problem. We have whistleblowers copying information on a vast scale. Everything's digitized and our challenge now is actually making sense of huge amounts of information. You'll see that ICIJ we're very much focused on using technology for that. I'm very excited for the possibilities of machine learning and AI for us to do better work but I think our challenges are in the midst of this implosion of the media at a time when the media is probably needed more than ever and I'm very grateful to the support we get from NORAD because without NORAD we wouldn't exist and we're a little non-profit and what we do is we actually bring stories to media companies around the world and then we use their resources and their reporters and their platforms to get the message out but I need to go to them with something exciting otherwise they won't want to work with me. There's definitely an appetite for it but it's a challenge for us to make sense of all the information that's coming to us. There's a huge amount of information on the dark web right now that would be of huge interest to everybody in this room but again that's another challenge. A lot of this information is coming through ransomware and it's a lot of Russian hackers that are doing the work so what is the challenge for us? Do we use it? Do we not use it? Do you use it? Do you not use it? Things like that. I attempted to come back with one follow-up question which we haven't really discussed before, but I was just listening to an interview yesterday morning with the mother of Jan Kuziak, the journalist who was killed, who was investigating on the basis of leaks from Panama Papers and there are of course lots of these stories around the world where journalism is not just journalism, it seems like frontline work where people's lives are at stake and it really shows the interest invested in tax evasion but how do you see this? Is it a dangerous environment for you as a journalist now? It's a very dangerous environment for a lot of journalists in lots of countries. I do think that there is a byproduct of our work has allowed journalists to get stories out that they wouldn't normally get out particularly in poorer countries, countries where press freedom is not great, by working as a consortium and by all working together we're able to get a lot of stories out that they wouldn't get out. I mean we had our own tragedy of course at ICIJ, Daphne Karawana in Malta, this is a reporter who wasn't working on our stories but then took our information and got our own further information and reported on that and it was to do with corruption in the Maltese government and then one day she got into her car and she was blown up. Now why it hurt us more than most is that her son Matthew worked for ICIJ and he was actually the computer programmer that had designed the system that allowed us to share the information during Panama Papers so yes in some countries this is incredibly dangerous work we've had to get reporters out of countries before publication some reporters are still working in exile now as a result of being willing to work with us on stories but I do think there is a certain protection also in working together we've got a number of instances where the owners of the media companies that we're working with were in our documents and when we first discovered that we were told we would never get the story out but by using the fact that ICIJ was going to publish it whether they liked it or not it allowed them to publish, the reporters to publish we've also had cases where the reporters have said there's no way we could publish a story on our own in a country or media publication will be shut down and then they give us the information, we publish it and then they find themselves in the strength scenario reporting what ICIJ is reporting even though they secretly helped us get that story I wanted to go there just because of course we need to remember people like Daphne and Jan and so many other journalists around the world because they're part of this group really in many ways and also to get a sense of how real this is in terms of the danger and the interests that are invested in it and you talk about on the one side the consequences of rallying feelings and the Daphne-Caronel case where she was not only killed but it was done in a way to clearly send a message, such an overuse of force and those feelings get that conclusion in a way become such a violent expression as well as mobilizing for change so there's this two-sided thing here going on at the same time it's both dangerous but also needed but I wanted to move to you Pierre now and you can come back to try to touch on this some of this later because all of this feeling and all of this loud debate about tax evasion and Alex will talk a little bit about how that is not only local and national level but also on a global level as all of you here know it's a good thing right you get dynamism around these questions and there's a tension but is there a sense you think that we sometimes crowd out the real knowledge the facts, the empirical evidence that we need to actually tackle the problem that all this noise or all this loud conversation actually can sometimes be to the detriment of facts what do we actually know about tax evasion and increasing domestic revenue Thank you Arvin So I think we know a lot more thanks to research than we did ten years ago on a lot of this issue and I think the first thing we've achieved is getting the right orders of magnitude around a lot of these numbers and that really serves to anchor the political or policy debate and you know then allow other institutions you know to start from the right starting point not wide exaggeration as you can think sometimes and not minimization as you can hear on the other side so let me give you a few examples of I think some of the numbers we now know that we did in five or ten years ago so one on the scale of multinational profit shifting we now have a pretty good sense that about a third of profits of multinationals are being shifted worldwide and this means that there's about 10% of all corporate income taxes are not getting collected that's something we know we also starting to know that the base erosion and profit shifting action plan has not really made a dent into this problem so that's something we've learned and I think Alex might come back to this in the face of the two pillar solution of the OECD something else we know that's even more staggering is the size of offshore financial wealth that is held in tax havens somewhere around 11% of world GDP so we're talking about really large numbers to that you might need to add a real estate offshore wealth and that's a newer field of investigation some people in the room working on this you know probably a bit of a smaller magnitude but growing in importance over time we also know that this offshore financial wealth and real estate wealth is really concentrated at the top of the income distribution for the holders within their countries and that this is a problem that impacts all countries in the world including a lot of countries in the global south and finally and that's somewhere where we merge earlier on on the research process when you take the whole tax system into account that is tax on consumption on personal income, on corporate income, on property typically at the very top for the top let's say 0.1% 0.01% of the population the tax system becomes regressive and sometimes quite regressive the very wealthiest pay less taxes than the other people in the top say top 5% of the population okay so this is I think a bit where we've come so far I think that really serves a purpose to anchor the debate and here's my quality of representing the EU tax observatory also funded by NORAD who we're very grateful for the support we're going to launch in October a global tax evasion report that will summarize a lot of what we have learned in the research in the last 10 years and also a website called the Atlas of the offshore world that's going to put all the data that we have in hopefully a digestible way for the media and for other organizations that want to use it so I think you know the second part of your question was can research influence policy and so here I want to focus on something a bit more specific a lot of the new resources could come from some coordination and global agreements you know there's the two pillar solution they was yesterday just talk about a global carbon tax potentially supported by the African Union of States but those you know could might or might not happen what a lot of countries can do including the global south is revise a bit the paradigm that it's impossible to tax the very wealthy and so start focusing a lot on high net worth individuals the three arguments often that governments might say for why it's difficult or impossible maybe to go after this segment one is just a lot lack of data and information on how much income and wealth there is at the very top these that we've made stride in this one really big achievement has been the common reporting standard of the automatic exchange of information that means that now almost all jurisdictions are sending information of financial wealth held in their countries including tax havens this is a recent development but in a few cases like for example there will be a paper presented about Argentina later that's using this information together with the tax amnesty these can make big differences Argentina is collecting repatriated by 20% of its GDP in offshore wealth thanks to that information so this is really you know novel and holds a lot of promise at the same time you know what about domestic wealth for example real estate wealth well we have much better technologies you know to assess disaster and property values and so on so I think we're in a very different space than we're 10 years ago this also requires of course investment for example in high net worth individual tax offices that are really specialized with this you know specific segment of the population argument number two is often how easy it can be to shift income between the personal income and the corporate income tax right if you're very wealthy you often own businesses too and you know where the income is salary or dividends or just retain profit within the firm that's fairly easy to do again I think on this there's the real promise of progress thanks to data again and the establishment of beneficial ownership registries that's something that you know has already happened including a lot of countries in the global south and will continue happening in the next few years that really holds the promise of unifying the tax base and as I said before getting a real view of the whole progressivity of the tax system including earnings that are within businesses something that was impossible to do in the past right and so hopefully bring really good data to the public debate and the third point that's probably the most contentious and difficult one is it's true that high net worth individuals can be mobile right they might just leave the country so let's here think about what tax systems do almost all tax system the world are going to tax their residents that is the first year where you leave the country you stop paying taxes in the country even if you spend maybe 40 50 years in that country that's where you met all your wealth and all your income the other extreme we have one country the United States that has the total opposite system right if you have an American passport you might just have been born there and spent three months you're going to pay taxes on your personal income to the United States the rest of your life there's probably a middle ground that can be found between those two solutions right and depending on how many years or where you made your wealth and income potentially you could keep on paying income taxes for a certain amount of years right and so this is arguably the most contentious part where I think economics has to work with lawyers and what's possible within the laws of each country but that would really allow to solve I would say that third objection for why it's difficult to tax high net worth individuals but I think you know maybe just to summarize what I've said is these are resources that currently exist we know that they are of large magnitude and it requires you know political will to go after them and investment in the right tax capacity Interesting period can I just ask you a question maybe it's too complicated to answer but why should we really care about this high net individuals because you know I remember from the time I was in government and we did this calculation about the difference between increasing tax to making a progressive tax on the highest earners versus simply adjusting the tax on middle class by one or two percent and because of the size of the middle class and that goes for most countries it will always be much much larger to increase the tax on the middle class than actually getting a progressive tax rate on the high net earners so how would you know what would be the political argument in a way or for that matter the research based argument for still going after the high net worth individuals because clearly and I think again I don't know if this is fact but it seems convincing to me that if your intention is to get the most possible amount of money in the shortest possible amount of time it's much less complicated to just simply tax the middle class a little bit more and then trying to go after the tax evasion and the tax havens because of course that's way beyond the control of most national governments That's a good question so first I'm not sure your initial hypothesis are quite correct so one reason is that you know you're thinking often of the current tax base that you observe in the tax data that's often much smaller than the true income or wealth tax base of these people in part because so much money is offshore right so you're not starting from the right number well you really observe the income of the middle class you don't observe that at the top of the income distribution the second reason is that if anything inequality has increased in the last 20 years or so so there's a lot of resources within a few hands and therefore a lot of potential tax revenue and the third and you know that circles back to what Toriel said or how you started having a progressive tax system is not really an option it's the only way you can make the social contract work right and the stories have broken out and people are actually now probably more aware of the extent of tax evasion at the very top if you're not going after this it's really hard to fix any other taxes you know how can you say I want to increase the consumption tax for example that really hits everyone when you cannot you know fix taxation at the top okay let's move to Alex I think this is a good time to sort of go up in the higher altitudes perhaps and you've been following international tax conversations for many years I would say decades even and we are coming up to this point where at least some of us have been you know sensing it's a critical moment coming where the international community has to decide on where in which basket to put their eggs and what solutions to seek but maybe start with the basic question you know do you think that there is progress coming is there any way we can get an international system that can avoid tax avoidance that was to you get away from tax avoidance or should we pessimistic or optimistic about this Alex I think I asked a question yesterday that was kind of the glass half empty right you know we made all these agreements in 2015 and we've done nothing since let me give you the glass half full version if we step back that couple of decades you know tax justice network was founded in 2003 okay so we have a 20 year period where you can see shifts and over that period suddenly things look pretty good right when we when we have a bit of patience we think about the kind of systems change that that Torrell talked about not the silver bullets but how these things move over time actually we can feel quite optimistic so step back I want to kind of pick up things that you mentioned at the beginning that others have said taxes are social superpower right it isn't just a bit of technical policy over here that we can do better or worse and you know nothing much changes it is absolutely central it may be the most important tool or set of tools that we have to organize how we live together as human beings so that we can all have better lives so when we screw up tax we really we're not just making a mistake on a technical question we're setting ourselves back as societies absolutely when we get it right we really give ourselves a platform to build and live better lives together taxes you know we talk about the four R's revenue you know to fund our public services redistribution to curb the inequalities and we know inequality matters not just because we want to take a bit from people at the top and give to people at the bottom but because countries with higher inequality have worse outcomes in a whole set of areas health and governance corruption all sorts of things beyond the narrow who has enough money question so revenue and redistribution repricing if we don't have effective tax systems we can't change the price of social of public goods and bads whether that's tobacco consumption or carbon emissions we can't protect our societies without effective taxation but the fourth R of tax is probably the most important representation as has been said I think by every speaker taxes at the heart of the social contract when we pay taxes and when it's visible to us that we're paying taxes so direct taxes on incomes particularly not just consumption taxes when it's visible to us we feel that government is spending our money and we hold them to account when governments rely more on tax as a share of their spending over time it's almost the only thing that is consistently associated with reductions in corruption and improvements in governance so governments don't just have more money they spend it better for us when it comes from tax okay so tax really matters then why is it that in a sense you know we would say you have seen progress even though I am so angry about so many of the things that we don't do yet it's because of you know the shifts we have seen in 2003 4 or 5 you know I'm writing papers saying I'm writing papers back in in the early 2000s saying why is tax neglected as a development issue why don't we care enough about this why are the IMF and the World Bank publishing tax data knows some countries as having tax to GDP ratios higher than 100% well the answer is because nobody is looking at this data to say that's clearly nonsense nobody is doing any research on this as a development issue tax doesn't get a mention in the Millennium Development Goals 15 years later tax is the primary means of implementation in the Sustainable Development Goals our understanding of the role of tax of its centrality to development and that's for countries at all income levels not just developing countries below some arbitrary level of per capita income okay so that's the big piece and underneath that there's a set of other changes pretty much all the things that the tax justice movement asked for 20 years ago were written off as tax systems and pretty much all of them are now on the table they're not delivered and certainly not delivered in an inclusive way but look we can go quickly through a set of things the ABC of tax automatic exchange of information about financial accounts in 2003 the only multilateral instrument for that for exchanging information about bank accounts was the EU savings directive only European countries had any access to that kind of information now as of 2016-17 we have the OECD common reporting standard so more than a hundred jurisdictions telling each other's tax authorities about their tax residence financial accounts offshore problems with that two big ones the biggest financial center in the world does not provide information to anyone in the United States arguably the biggest financial secrecy jurisdiction certainly top of our financial secrecy index and at the other side most lower income countries are still excluded Malawi to take one example cannot access information about Malawi and tax residents Swiss bank accounts because of the spurious reason that the OECD imposes which is that Malawi is in a position to tell Switzerland about Swiss holders of Malawi and bank accounts as if this was a serious issue as if Switzerland or anybody else was thinking I must find that out before I give them any information so we have this we've achieved the principle of automatic exchange but we haven't made it inclusive or effective beneficial ownership we're on the road we now have registers for companies for trusts and other legal vehicles in many countries but we're not fully there yet so on the road but a lot still to be done that's B, C is country by country reporting you know we have this now in principle that multinationals have to report their economic activity their profits and taxes paid for each jurisdiction where they operate but that was always a proposal that we've made that the data be public because fundamentally it's about people being able to hold their own governments and multinationals to account instead we have an OECD standard that makes the information available only in the first instance to the tax authority in the headquarters country which is almost always an OECD country that country can then exchange the information with others but you'll never guess what sort of countries never get that information or get it three years after they've done the audit well it's lower income countries who are not in the OECD so instead of and Dominica presented really interesting results on this the other day it looks like country by country reporting has actually made profit shifting out of lower income countries worse which is what you'd predict if you only give the data to OECD members of course they're the ones who are able to benefit by pushing back on the profit shifting at the expense of other countries so we need that data to become public but again we're on the road something that was impossible that nobody understood 20 years ago you had to explain it to them from scratch is now part of the international structure the question is just how we make sure everyone gets that data gets the benefits of it okay the bigger pieces and I'll wrap up are really around how we tax unitary taxation taxing multinationals not trying to allocate the profits to individual entities which is not what multinationals do but taxing them at the global level and then apportioning that profit as tax base between the countries where the real activity takes place this is the road that we're on the OECD two pillar proposal includes that principle for the first time but in effect the two pillars have already failed pillar one which should do this will never come into effect because it depends on the US applying it and that won't happen even if it did it would only apply to a small bit of the profits of less than 100 multinationals the G24 proposal was to apply to all profits of all multinationals and that's eventually where we're going that is the road but there's a long way to go and finally on governance you know we called 20 years ago for a World Tax Authority as Vito Tanzi of the IMF had done in 1999 as the Zedillo report did as the G77 group has done for two decades or more we're not there but last year the UN passed a resolution unanimously to begin intergovernmental discussions on an international tax cooperation framework under UN auspices finally to take tax rule setting out of the OECD and put it in a globally inclusive setting we're not there yet and we hear that OECD members are mobilising against starting formal negotiations so the fight is now with us we're not, we haven't won but we're on the road and it's clear that this is the direction of travel we may not start formal negotiations this year but that's where we're going we're in a position where the OECD sets the rules and creates the standards but the evidence shows us very clearly that the biggest, the most the country's most responsible for the tax losses suffered globally are OECD members and their dependent territories OECD members also lose the most in absolute terms and their citizens are big losers but it's lower income countries who lose the most as a share of their tax revenues as a share of their public spending including on health and in terms of impacts like unnecessary child and maternal mortality the social superpower is most badly lacking in the countries that have the least power to change the rules today and that's why we're on this road it's why we will end up with globally inclusive decision making at the UN the question really is how long some OECD members prevent us getting there but we are going to get there because our glass is half full it's just a slow, slow drink we're having Wow, what a metaphor how slow though is the question isn't it I mean if this takes 50 years Alex is it really worth it I mean I'm a UN staff I'm not supposed to say this but the UN is of course a place where things take time for natural reasons everyone needs to be consulted everyone needs to be part of the conclusion on an institution that clearly has at least managed to get people around a set of rules yes it's a subset of the international community but why not gamble on that I mean I think that's on the face of it seems like a better gamble if it's going to take 50 years to get it done in the UN that's very provocative Arvin in 2012 that's the gamble that the G20 took even China which always resists a delegation of responsibility to the OECD agreed that the OECD was the only game in town we will ask them to do the base erosion and profit shifting action plan and solve this problem for us the G20 gave the OECD one goal to reduce the misalignment between where multinationals have their actual economic activity and where they declare their profits as Pierre and others at the tax observatory and other researchers including Gabrielle Zuckman have shown very clearly things have got worse since then we have had 10 years at the OECD not at the UN in which things have gone backwards we've done a lot of talking we've come up with some great technical standards and things have got worse so is it pragmatic to say let's give the OECD a third chance you know let's have BEPS 3 because maybe they'll get it right this time I don't think that's pragmatic I think that's you know it's it's committing ourselves to fail further so let's be fair the OECD is not on stage here but let's see that for a moment because I think we're running out of time and I want to have time for at least a couple of questions from the audience in a few minutes so prepare yourself for that I want to ask the panel about this piece you know to what extent can developing countries and developing country governments get involved in these processes I mean how can they get agency and Toriel I'll go to your first and one of my reference points for this was 10 years ago actually I was a part of this African Union high level panel on illicit financial flows together with the former president Tauban Beki of South Africa and we travelled around the continent we visited all these countries and we sat down with cabinets full cabinets in fact very often the entire cabinet for one or two days and discussed this issue with them and I remember in one particular case where in this case it was only Beki and myself who was travelling and we went to this let's call it a little louder than medium sized African country and we sat with the full cabinet including the president and the prime minister and we discussed for a full day and two days actually after a day and a half the president just stopped the conversation and said now I finally understood something I haven't understood and that is how five of the mining companies in my country hasn't reported a single profit for 15 years so two things about that one it's terrible that they haven't reported profit and therefore pay taxes but the other is that it took 15 years for that government to feel empowered to do something about it or at least even enter the conversation on it so I wanted to ask you it's finally doing this gambling on us and many people here and of course there are government representatives from developing countries here but to what extent is it important or to what extent is it possible to actually help the ambition of engaging in this conversation and being part of setting the global agenda on the side of developing countries and can an outside actor like Norway be a force for that? I mean let's just say yes absolutely yes there is definitely things we can do and participation at the global level and at the global normative standards I think has to come from a domestic debate and at the national level it requires what we call like the ecosystem of stakeholders that has the capacity and access to knowledge and information to actively then participate in a public debate one of the challenges is of course that it's a fragmented agenda between different ministries you need to really tackle tax evasion in our country is a ministry of finance for domestic to take care of our domestic resource interest ministry of foreign affairs to a certain extent on the development side ministry of justice in terms of following this and taking actions and prosecutions so it's a complex area and what we see and I think one of the things that we can do better at in order to create this atmosphere and environment for this national debate is information sharing and transparency around data on the one side and then capacity having that capacity to access and understand and transform this data and knowledge into positions I don't think that all countries need to necessarily end up with the same conclusion but I think it's important that countries have a national debate that inform their positions in the global stage a fragmented part where tax administrations or ministry of finance go to the OECD and negotiate and ministry of foreign affairs or heads of state go to the UN and negotiate this isn't going to get us forward and I think civil society plays an important role here research, journalist and so on to look to show this interconnectedness but information sharing also between government entities is a real weakness that we've found because information is power and sharing information between the necessary entities within government isn't happening to the extent possible but the transparency on the data so that it's not one government entity giving the data to another but rather that it is publicly available or transparent will I think facilitate this and I think there are things definitely there we can do and also shifting so bringing more of the actors that we support that are not the tax actors but that are the actors in the anti-corruption space on the climate financing into the discussion and that's also I think something we can do as a donor country engaging on that Any other comments on this? I totally agree it's about transparency I mean we give the example of the African country not knowing for 15 years what had happened I can take a guess what happened somebody got a bribe at the beginning or a contract went out or something that allowed the mining company to do this the only way to tackle that is through transparency these mining companies all of their actions should be made public and not just to governments but publicly available so journalists can actually analyse everything and see what happens what's going on here is that the money from the poorer countries is going into the richer countries I've seen documents that show like investments in Wall Street companies by people who are on sanctions lists and because it's not really worth the US they want the money to come to their countries so they're not going to tackle it I do think there has to be this global approach to it there has to be an international body that says enough's enough you cannot just allow it to happen at a local level it's got to happen globally Any thoughts? No? Alex? I know you have thoughts on this I always have thoughts I think one of the things that has shifted is the availability of information about the scale of the problem and that does drive engagement coupled with really importantly the stories of individuals I can say it's 100 billion and PWC say yeah maybe it is, who knows but Gerard can say Apple did this and then they spoke to Appleby and then they looked at this jurisdiction and that's different people understand in a different way but I do want to stress there's a lot to win for OECD countries as well this isn't just shift in the balance you know to that story of 15 mining companies I raise you the UK in 2014 and this is the last time that we have the full data for this 70% of the assets on company balance sheets in the UK were on the balance sheets of affiliates of multinational companies that paid zero tax so 70% of the UK's corporate assets were of companies that were paying zero tax in the UK 2014 was not a low profit year in the UK to be clear this is an indication it's a number that people don't know there's no anger about that number but it's an indication of the scale of profit shifting that the UK facilitated and continues to facilitate and it goes unquestioned because that sort of number isn't in the public discussion and it's probably much worse in a sense in terms of the implied revenue losses than even a country dependent on a few mining companies so there are wins to be had for everyone by fixing this information is a key part of driving the political attention to it and the last issue with the OECD is that the negotiations are so opaque that nobody knows where the governments are doing in the negotiations what they say publicly the main benefit of the UN and that's not a criticism of the OECD it's just not set up to do publicly important negotiations the UN is when governments are accountable for their position in international negotiations to their domestic audience you'll get a shift politicians don't see the light they feel the heat and there's no heat in the darkness at the OECD but there can be at the UN and that's again it's where we're going that's great so we can open up for a couple of questions if you have Lumi there at the back with a microphone I think can I just check is it Risa who has the online questions are there any questions there are no questions so then let's take a couple so let's call them questions slash comments but if they're comments they're not full feces explorations right they're actual short comments so please go ahead does anyone have any thoughts they want to share there's one over there yes thank you my name is Jacob Mieter from the University of Munich thanks for a fascinating discussion I have a question concerning this point about high income countries benefiting more for example from the common reporting standard than low and middle than low and middle income countries okay so this dichotomy between the rich countries on the one side benefiting more from all these regulation attempts compared to low and middle income countries on the other side now I'm really not sure that that's the case so the research I know on tax evasion and tax avoidance is very unclear on any benefits for high income countries of tax evasion and tax avoidance I'm there are at least two points where it hurts first when the tax doesn't get paid and so people don't do what you want them to do for example they smoke because they can evade the tobacco tax then when the money comes back from the tax haven and the storage markets all over the world including in high income countries and so in my reading tackling tax non-compliance is a win-win for democratic societies no matter how wealthy so I'd like to know who you actually think benefits yeah good comment I think this is also speaking a little bit to what Alex was saying but let's take a few more if there are any Hector Thank you Hector from Scatifosh Center for Tax Research I wanted to ask a little bit on the governance side because we have more information and the governments can't have access to understand more of the scope of the offshore wealth for example and they can try and enact some reforms at the country level to address this the reality of some developing countries I'll use the example from Latin America that's where I'm from and where I know then you have another reality which is the political sphere which is usually ruled and there's a lot of power in the economic elites that have benefited from this lack of transparency for many years and what you see then is quite a violent political reaction to stop these reforms where governments even when they have the support from the electorate and they have the information and the good policies that they want to enact in reality they're not able to come forward because they're stopped at Congress or in some cases even you see for example Colombia and Honduras recently there's even talks about military coups once they take these discussions so in the political sphere then how can we also collaborate to help these countries that want to enact these reforms when we know that the economic elites and the political reality is quite harsh and they don't have the level of governance that maybe other countries have when they enact these kind of policies. I'm going to be cheeky and ask you to try to answer the question yourself just leave the microphone with actor because it's a certain important one and it seems like you've thought a lot about it I mean what would you know is it possible for you to try to help us at least identify where the answer to that question is it's super complicated and extraordinarily important but yeah please go ahead My immediate thought is around who is benefiting from all this wealth that is coming out of the developing countries and how right now in the current system it is these individuals can do that they can't have offshore wealth and there is a benefit in these countries that are receiving this wealth and then can use or have access to those funds so my immediate thought would be on how can we really convince these countries that are benefiting from having offshore wealth to put a stop to putting the homework or the task on the individuals that want to have that offshore wealth it's harder for them to find where to put it and how to then take it out of the countries so I think that kind of cornering these economic elites that are used to this in a position where they cannot do it to the same extent and then you have also information on what is the amount of wealth that they might have outside you're kind of helping just cornering them into a situation where they're easier to enact these policy reforms but at the same time it's very hard when you put in the violence aspect which I think it's very relevant in many of these countries and that really pushes politicians back and for that one I don't have an answer on how to fight it back Thank you, thank you for that there's one more here and then I think we'll go back to the panel let's take the two here one in the back and one immediately in front Thanks my name is Christina Berger and I work for the Extractive Industries Transparency Initiative we're also celebrating 20 years this year as a tax justice network there's more good news more and more countries that implement the ITI standard are publishing contracts so mining companies, oil and gas companies this data is coming out we also have 20 years of data and as also mentioned more and more countries are publishing their beneficial owners so we're sitting on loads of data but what we've seen in our countries is that they're not really leveraging that in a way to identify companies that are not paying dividends to the government for their participating interest for example or the right revenues on their corporate income tax this data is hardly really analyzed and leveraged so my question to the panel is how can we change that how can we bring more of this technical knowledge translated so that it's actually understandable and it reaches the right audiences so that people get angry and want to change something about it and the second question is how do we get EU countries to give public access to beneficial owners after the ACJ ruling maybe there's some appetite on that one as well thank you thank you so much it's an interesting discussion yes tax evasion can best be handed through exchange of data and the issue is there are so many requirements so many boxes to take off for us for some countries like mine Uganda to be allowed to exchange automatically for example for example Uganda to be allowed to exchange automatic exchange of information so many security requirements and this takes so long for example we've been discussing this we've been going through assessments of making sure as an authority we are ready to automatically exchange and up to now we haven't and I was just asking the panel is there a possibility if we do this as a bloc and probably the requirements for exchanging for example the data security requirements are kind of grouped based on the kind of country we are talking about because with all these sets of requirements that you need to meet before you automatically exchange it takes so long for some of us to actually get there and so the exchange is delayed thank you so much super interesting question okay so we have 506 issues here and 9 minutes and 4 panellists I suggest we do it this way that you pick and choose and of course pick up conversations afterwards with the people who've asked the questions and we just start in the order that we did the introduction so we're going to start with you to it okay I'll skip the most difficult questions no I'll try I mean it's I think it comes back to this that not everything can be solved through a tax lens building a strong governance systems that has both state and non-state accountability actors with the right capacity like supreme audit institutions and a strong civil society that is protected and not targeted and it comes back to this we need more people we need more people than tax experts to solve this problem and we need to engage and connect with that elite capture and this kind of regressiveness of political elites that are also often economic elites is a huge problem and I think transparency can help partly but we have to look at transparency I think it's important but we should be a bit strategic also about having supporting the transformative transparency initiatives where we think that there is an actual possibility to uptake and lead to actions and change a lot of developing countries are also overwhelmed with the information in some cases there is a lack of information in some cases there is an overwhelming inflow of information that is not useful and then maybe the solutions gets lost in that but I should say like this we added from the first initiative agenda to the second we added the focus on the state and non-state accountability actors because I think this is important civil society cannot do this fight alone we need to also invest in parliament in supreme audit institutions institutionalizing that kind of accountability and then the knowledge for the solutions at the country level knowing the political landscape and the political economy to inform the policies and the processes at the country level has to come from countries themselves and I think all the multilateral partners we as donors we need to make sure that this is the driving principle locally led processes that can absorb the nuances around this information and then make the better strategies to hopefully get better policy decisions locally and better participation or more strategic participation in the global processes Thanks George Yeah look I mean I'm going to let Alex and Pierre answer the big question there which is no evidence that rich countries are benefiting I've seen that evidence myself it's all anecdotal evidence I don't have the I'm not a PhD like these guys but it's there I only a few days ago I saw a list of all of the investments by one Russian oligarch and it's two billion dollars and they're all Wall Street firms that he was investing in that money is definitely going there we've seen evidence of farms, vineyards all across Europe that are owned by people from poorer countries mainly because they don't trust their own political systems they're worried that they're so corrupt that somebody even more corrupt will come along so they have to get out and they have to hide that money for their children that's what happens the second question in relation to we're in a country with a very harsh environment and you can't bring things out my answer to that is what we do international embarrassment we found that a country will often react to the international media in a much stronger way than if they themselves if a local media was reporting on a story no reaction if it's CNN if it's the Wall Street Journal or if it's the Washington Post suddenly you do get action because it's internationally embarrassing for them in terms of extractive industry and patterns are what brings out new stories or investigative pieces for us so we always use technology to look for patterns and I think when you have good data I think what you have to do now is invest in technology to look for those patterns because when you find the pattern that's when you've got to find something that is a public interest the fourth question in relation to box ticking I would argue very strongly you've got to be very careful when you introduce new rules and then you have people who say they comply by the rules again we saw evidence you know when new rules were introduced as a result of our earlier stories and then we were able to see how later firms were applying those rules they were going out of the way just to tick the box so they would for instance Google Jared Raul on literally Google my name exactly get that exact thing that's all they had to do they didn't look for variations of my name and things like that if I was a criminal by the way so I think they always know your client rules basically the evidence we were seeing they were doing all they could to get around it in other words the corruption got more sophisticated every time we revealed corruption and I think you have to be aware of that when you're setting new rules you've got to counter that from the very beginning sorry that was a lot I'll try to answer the harder question the political economy and what I think research can contribute at least and so coming back to this point that information is power for civil society I think there's one thing that increasingly we can do which are those distribution incidents maps so I talked about taking all the taxes you have in the country increasingly that's possible we have beneficial ownership data we have some data from the CRS on offshore wealth and really plotting just these simple figures that show including at the very top for the top 100 most wealth individuals in the country what is the true effective tax rate they're paying so this is an exercise that has been done in very few countries there was recently one in France for example even in France often thought as the highest tax country some Scandinavian countries at the very top it's about a 25% effective tax rate versus a 50 or 60% for the top 1% this is an exercise that probably we can't do yet everywhere but the EU tax observatory working with Latin American countries precisely on that and there is a will there's a lot of left-leaning governments currently to do this exercise if you're able to do this year after year with trustworthy data I think that's a real data point that cannot be refuted by the politicians so you know the type of patches they might put and say well we did this so therefore we're going to improve inequality and equity and so on well you can really hold them accountable including at the very top and I feel from the research or kind of policy side that's probably one of the best inputs we can give to civil society Alex I'll try and be quick Jacob the CRS the common reporting standard I think the OECD would say it has generated additional revenues over a hundred billion dollars I think we could argue about the number but there's significant genuine benefits we've got more than a trillion euros of assets of incomes now being of assets in financial accounts now subject to exchange that has to be progress on the other hand you know you're right the evidence shows the biggest thing that's happened is that people have shifted their undeclared accounts from other places into the United States because it's the easiest the best place now to do it so you've squeezed the sausage but you haven't made it the amount that's hidden any smaller you know if you go back to 2016 you find all of our pieces saying that that will happen saying that people will exploit golden visas in order to pretend they're citizens of somewhere else that doesn't do information exchange and that Swiss banks and others will create things that look like financial accounts but are not reportable under CRS all of these things have happened and happened at kind of great volume so we need to think about this it's not a silver bullet in place and that's it this is basically a form of capital controls and we know with capital controls every year somebody finds another way around it so every year you have to tighten it up the OECD has done a bit of that but they need to do much more they need to be much more responsive to what the research by Dominic and others shows very clearly that these methods of exploitation are being used and are growing because the response isn't coming but ultimately on the point about Uganda we need to make this globally inclusive it cannot be continuing to exclude countries particularly with these spurious demands for meeting confidentiality standards or reciprocity what we've argued for is there should be something like a three to five year window in which you can access the information without reciprocating without having to reciprocate to allow countries to see whether it's worth it whether it's worth them investing in the systems because of the benefits they'll get at the moment you can join and actually none of the other signatories have to give you any information it's not a requirement they can pick and choose and decide not to give you anything and so you don't know what you're getting you're being asked to make this investment up front to find out whether you actually get any information that's worth anything at all ultimately again this has to become part of the UN tax convention and to be required to be globally inclusive without these kind of hurdles but that's the next step I guess I'd say the same for beneficial ownership but the European Court ruling is a real obstacle and it's made it the ruling said that the human right to own companies anonymously trumped any other argument about beneficial ownership transparency and this was an argument put forward by notorious law firm involved in hiding beneficial ownership on behalf of someone who is their beneficial ownership on social media very often and their great wealth so not a very convincing story but it set this precedent policy makers in the EU are now actively working against that for the rest of us it should tell us that we failed to make sure that the human rights argument in favor of beneficial ownership transparency was the dominant one there is a very clear human rights argument we know that markets and states don't work when we allow anonymous ownership and that that has all sorts of impacts not only but largely through tax losses on human rights if we're not making that argument nobody else is going to and that's a failure that we have to address so there's work to be done but I would say still I feel like we are on the road with that we probably didn't do justice to those questions properly so I recommend that you have this conversation in the break we have a 25 minute break now all that's left for me to do is to thank the panel Alex Toulou here and Gerard for a good wake up session for all of you and there's lots to take on forward into the other breakout sessions after the break so thank you very much for being with us here and online