 Okay great well welcome everybody to our panel the title of today's panel is Global Tax Reform Stalling. I'm going to give you a little bit of context before I introduce all of our panelists today. In October 2021 almost 140 countries in the world it isn't quite 140 it was actually 136 to be precise. Agreed to sign up to a historic OECD agreement on international tax reform which aims to ensure that multinationals pay their fair share of tax and help countries prevent corporate tax avoidance and evasion. Now I had two pillars the first pillar pillar one which gives market jurisdictions further taxing rights on digital profits. Pillar two which is essentially a minimum corporation tax of 15 percentage points for multinationals so long as their revenues meet a certain minimal threshold. Now I thought it was this interesting that this week the OECD put out new numbers saying that pillar two so the minimum corporation tax should result in annual gains of over 220 billion dollars annual gains that is versus their initial estimate of 150 billion dollars so it's been revised upwards. Pillar one the digital tax is expected to lead to annual global tax revenue gains of between 13 to 36 billion dollars of profits of about 200 billion dollars as well. Now it must be said that in December the EU also reached an agreement in principle to implement pillar two in a way that is consistent and compatible with EU law. So where do things stand today? How much progress has there been since October 2021? Are we going in the right direction? What is the future for this tax proposal? Those are some of the questions that I hope to get answered during this panel today so I'm going to start off by introducing our panelists. First of all we've got Mattias Corman the Secretary General for OECD to his right. We have Zainab Shamsuna Ahmed the Minister of Finance, Budget and National Planning of Nigeria. Welcome. We have Gabriel Zuckman the Director of EU Tax Observatory in France and Faisal Elbrahim the Minister of Economy and Planning of Saudi Arabia Young Global Leader as well. Mattias I'd like to start with you. First of all can you just give us an update on the progress that has been made since October 2021. How would you characterize the transition from commitment to actual implementation and of course I'm guessing that the EU commitment in December was a step in the right direction. Well look I remain quietly optimistic that we will be able to reach the targeted implementation time table of 2024 for pillar one and pillar two. I mean in terms of the opening question is global tax reform stalling. My answer to that would be no but of course I mean global tax reform is difficult to achieve. It was never going to be straightforward. There was an agreement in principle in October 2021 which was indeed historic. It was a commitment to ensure that our international tax arrangements in a digitalized and globalized world economy are fairer and work better and in particular that there was a fairer distribution of tax revenues into market jurisdictions. Now in relation to pillar two I mean you've mentioned that 27 EU member countries have now agreed by unanimous consensus to implement the agreement which comes on top of countries like the UK, Switzerland, Indonesia, the UIE, Singapore, Korea, various others. And so I mean I believe that there is now very significant momentum around the implementation of the pillar two and pillar two is designed in a way that makes itself perpetuating because it gives the right to those countries who legislate the pillar two to collect revenues that haven't up to 15 percent of profits that haven't been collected elsewhere for those countries that have legislated that deal to collect those revenues and so it really becomes a matter of self-interest for countries that haven't yet legislated a pillar two in terms of their desire to protect their own revenue buys to follow suit and also press ahead with legislating pillar two. Now in relation to pillar one that's the most complex work it requires a multilateral convention. We hope that the drafting process of the multilateral convention can be finalized by the middle of this year. There's still some you know various areas where there is technical discussion. There's some public consultation processes currently under way. For example on issues like how do we treat withholding taxes. You know those who pay tax in market jurisdictions say that withholding taxes are taxes that they pay. They should be taken into account. Others say they were not in scope and really if withholding taxes are part of the equation then we should adjust the amount. I mean it becomes very technical very quickly. There are some discussions around you know obviously for those companies that will be required to pay more tax in market jurisdictions the upside opportunity and the interest for them is to get tax certainty where there is a more consistent approach internationally. But then that means that those countries who have or who might be considering to pursue unilateral digital services taxes that they either should not proceed or indeed withdraw those digital services taxes. So there are conversations around this and you know various other aspects. I'm not going to bore you with all of the detail unless you have some more questions about it. But the bottom line is this you know a multi-lateral agreement that is swiftly effectively and you know widely implemented is clearly in the interest of the global community. It's the best deal that is currently on the table. We've got to be very careful not to let the perceived perfect be the enemy of the achievable good that is currently on the table. And in my my my proposition to all is that this is really the best opportunity that global community has right now to improve the way our international tax arrangements work in a digitalized globalized world. You were just this thing the countries that have made significant progress. One country stands out for not being there and that is the US. Were you disappointed that the US who were so instrumental in pushing this agreement forward didn't actually include it in the inflation reduction act. They included something similar but it doesn't subscribe to the same elements. Well I mean the United States has legislated a form of minimum tax. You're right. It's not entirely consistent with the provisions of the global minimum corporate minimum tax as designed and as a great in the context of the OECD process. But you know we are part of the work that is currently on the wise that put in place appropriate bridges between different regimes to make sure that there is consistency in application. And when the democratic process is in the United States and the same wires in other parts of the world will of course continue to play out and we would like to see all the countries that have signed on to the agreement to fully you know ultimately to fully implement both pillar one and pillar two. Once the multilateral convention is in place for pillar one and indeed pillar two can happen as of now. Minister I'd like to turn to you now. Nigeria was one of the holdouts on the deal. Can you explain to us why and also what prompted Nigeria to go to the UN on behalf of other African nations to put forward a motion at the UN level to go ahead and do their own form of international tax reform. Well let me thank you for inviting me to be part of this session and also for the opportunity for us to speak to how concerned we are about this process and to emphasize that Nigeria is still on the table is still engaging the process and just seeks to have some improvements that need to be done to consider how this rule affects developing countries like Nigeria. The original intention we were told was to allow taxation of digital enable businesses in market jurisdictions and to understand the main challenges and obstacles facing implementation of tax agreements across the world. The question that we need to ask now is has this key objective been achieved by this arrangement especially considering the substantial percentage of digital enable businesses that have been excluded by the scope. For Nigeria the answer is we cannot sign up to this in the way it is now but if there's improvement we are on the table and we are interested in still joining and the reasons for us are one the negotiation contrary to the agreed rules was not based on equal footing. The laws that evolved did not carry the views of a lot of countries along so mostly what is meant is the views of the developed economies to the exclusion of most of our own countries. The current agreement also does not deliver on the underlying objective and the rules developed that are developed are so complex that it is difficult for us to cope with its with the implementation so the rules need to be simplified. The pricing and the implementation are beyond our capacity to cope with right now and also the narrowing of the scope of the rules that medium-sized digital enterprises that dominate our markets are excluded. Most of the enterprise digital enterprises in our countries are the medium-sized ones that they're not the very very large ones and the outcome of this means that there will be also discriminatory taxes within our own jurisdiction so we will not be able if we sign up will not be able to tax this medium-sized and small-sized businesses while we are taxing similar companies that are Nigerian companies under operating in the same market so these are things that are important to us and need to be looked at and maybe some variation of the rules or maybe some stratification of the rules to meet the needs of developed countries. The agreement also seeks to prevent our countries from taking any step to tax thousands of out-of-scope digital companies and for us that's where most of our revenues are right right now so we have issues that need to be looked at and we hope that the rules that are currently designed to be pro-developed countries will take into account the needs of our countries for example the income inclusion rule and the ordering of the Peler 2 which ensures that little or no taxation right is preserved for the source countries with this unfair design of the rules and the limitation of the scope to subject to tax rules the IRR that will be used by developing countries by developed countries will simply be used to mop up taxes from our countries and we will end up with very little or nothing at the end of the day so these rules are important to have global rules but it's also very important that the rules should be fair and the rules should encourage tax equity and as much as possible accommodate the various variations of countries that are sitting on the table. Very clear I will give you a chance to respond but first I want to go to Gabrielle you've done a ton of work on global taxation November last year you published a paper called Global Profit Shifting which has showed that profit shifting has dramatically increased since the 1970s essentially when a multinational moves its profit from a high tax jurisdiction to a low tax jurisdiction to what extent do you think the OECD proposal is going to stop that type of behavior and I guess the same question to that as a follow-up is are you expecting multinationals to change the way the the way they behave on back of this proposal. Yeah thanks thanks a lot for the opportunity to be on this panel and I want to start by saying that this agreement is really a step in the right direction it's the first time that there's going to be an international agreement where countries agree on a minimum tax rate we have many treaties that are about everything except tax rates which is really what matters the most you know for tax policy it's going to make a real difference especially pillar two because many companies today pay less than 15 percent in taxes at least in some of the countries where they book profits and the reason for that is because there's widespread profit shifting to tax havens we estimate with my co-authors that each year almost 40 percent of global multinational profits are booked or shifted to tax havens where they are subject to very low tax rates you know of five percent or so so this agreement is going to make a difference that being said it's also very insufficient and it's also conceptually and philosophically flawed it is insufficient because a tax rate of 15 percent is way too low in many countries the the ratio of taxes to total income is 30 percent 40 percent 50 percent which means that most social groups you know the middle class the working class they pay 30 40 50 percent of their income in taxes now we are saying for multinational companies it's okay to pay only 15 percent multinational companies some of the most powerful economic actors who've most benefited from globalization it's okay for them to only pay 15 percent it's very hard to understand for people and for good reasons so that's the first issue the second issue is that in practice multinational firms will still be able to pay significantly less than 15 percent and the reason for that is the the big conceptual problem with this agreement which is that not all profits are going to be subject to 15 percent there are caravans which are very large and i want to explain that very quickly because it's a it's a really important philosophical question and i'm going to explain exactly what i mean by that the caravans mean that if you have sufficient activity in a country you employ people you have assets then the profits that derive from that activity are not subject to the tax the 15 percent minimum tax or at least not fully subject to the tax the underlying kind of philosophy behind that is that tax competition when it's real you know when it's real factors of production employees assets moving to low tax places is legitimate and there should be no floor to how low taxes can go even tax tax rates of zero percent are acceptable and i think this is the big problem this is the big problem because if we keep having a form of globalization where there is no floor to tax competition it means that who's going to keep benefit the most from globalization well the most mobile factors of production multinational firms they are shareholders people who are at the very top of the income and the wealth distribution and so it's going to fuel you know to keep fueling inequality and eventually this is not sustainable so that's that's the big problem can i just ask you that 220 billion dollar that i mentioned at the beginning is is that can you contextualize it for us is that a decent sum to be raised from this type of overhaul and it's it's it's decent and i want to stress again that i i do think that this is a step in the right direction so 220 billion dollars in extra revenue and we obtain very similar you know estimates in our own work in the context of the EU tax observatory so we think this is realistic that's almost 10 percent of global corporate income tax revenues that's a significant amount of money yeah that's for pillar two pillar one you know most likely will generate significantly less revenue but for pillar two we are talking about significant revenues and the reason for that what it means is that you have many companies that pay much less than 15 percent today uh last week the government accountability office in the US released a report where they estimate that the effective tax rate for US for large US corporations after the 2018 tax reform in the US has been 9 percent 9 percent so you know it's below 15 it means 15 is going to make some difference but of course the big problem is why only 15 there could be much more revenue if it was 20 25 i want just to finish with that last thing in the mid 1980s the average statutory corporate income tax rate globally was above 45 percent today we are around 20 25 percent okay and we're saying well there should be a minimum of 15 but historically we've been way way above that okay i'll come back to that Faisal i'd like to ask you about where Saudi Arabia stands in terms of implementing this deal and i think it's relevant because there is sort of a critical mass that's required for this deal to be successful is there a bit of a i'll go if you go mentality i'll be very frank with you Saudi Arabia broadly supports this there are some details that need to be sorted out but we broadly support this because uh it stands it's underpinned by the pillars of fairness this is all about making sure that value and and taxation are are close to each other and in that regard i think uh in Saudi under vision 2030 we've been focusing on detaching ourselves from the traditional sources of revenue with our economic diversification to think about more long-term sustainable revenue generation but also diversifying our source of growth so this will as a byproduct push governments to think about true fundamentals of competitiveness and competition at the same time so this this will drive productivity this will drive competitiveness this will take us away from the environment that had that race to the bottom with being too attached to uh fiscal incentives now i agree we have to make sure everybody's at the table and listen to everyone one thing we learned in the last seven years is that uh voices are heard uh and collaboration really yields results so broadly we're we're uh supporting this direction we agree this is a step in the right direction uh we feel that we have to stick to the timeframe that's been set up with a multilateral agreement by mid-23 and and implementation at the start of 2024 Matias i'd like to go back to you so there's a lot coming at you namely that you know the one of the criticisms of the deal is that there are many carveouts for example i read on on pillar one once you adjust for all of the minimum threshold etc you basically end up with a very small pie of around 69 companies that will end up being taxed that's that's in pillar one and the bulk of it is coming from us big tech firms so it is a global deal but in that from that sense a local impact uh other pushbacks we heard from Gabrielle saying that 15 percent is is too low and many many concessions were not given uh to represent african communities how do you respond to all of this well firstly i mean we've always said and we still believe that there's about 100 of the world's largest more successful multinational corporations that are in scope for for this deal and it is a very substantial reallocation of taxing rights and and pillar two as you as you've mentioned we expect now to deliver 220 billion dollars us per year in additional revenues mostly benefiting low and middle income countries now you know some people have argued all the way through instead of 15 percent we should have 20 or 25 percent you know what i mean in the end you got to get consensus on something that will be implemented and 15 percent is substantially better than 0 percent and i mean what we're trying to address here is you know a history now of tax evasion and tax avoidance which has become much easier in a globalized digitalized world economy and you know in terms of the comments that remind i mean we very much appreciate our work with nigeria nigeria is deputy chair on the inclusive prime work steering committee half of the members of the steering committee are developed economies more than half of the members of the inclusive framework are developing economies and you know these are the decisions in the inclusive framework are made by consensus now that makes it more difficult it makes it more involved but and we are very committed we will continue to engage with nigeria and with others in relation to some of the outstanding issues on which we still are yet to reach consensus now we do believe though that for countries like nigeria this is an incredibly positive deal that is on the table i mean nigeria right now that has one of the lowest tax to gdp ratios in the world 5.5 percent 5.5 6 percent across the oe city on average it's 34 percent across african countries in the broad it's about 15 16 percent now we believe that both on the pillar two and pillar one as currently designed the nigerian government will have substantially more revenue available to deliver investment public services and social protection to its population now it's true i mean we can continue to have an argument you know around the world for a very long time that will never reach a landing and we remain stuck at a level where we say okay we want the perceived perfect instead of pursuing the achievable good that's on the table what i'm suggesting is this is this is a deal that has the that has the most realistic prospect of any other deal on the table to actually make a tangible positive difference let's make it happen yes let's continue to work constructively and in good faith through some of those technical issues that are on the table yeah but ultimately let's not don't let's not let this file let's make sure this succeeds why was there a carve out for uk financial services well you know in the end this is this is not we're not talking about carve outs here about specific there's a carve out in terms of pillar one of regulated financial services and of extractive resources the resources sector now what we're trying to achieve here is to address the risk of tax evasion and tax avoidance in relation to very mobile activities and in particular i mean that's why the digital industry was so much in scope i mean the example that was just mentioned i'm not aware of countries that would tax at zero percent businesses in their jurisdiction with physical activity in their jurisdiction as part of an effort i mean businesses activities that can't easily shift to another jurisdiction are not the sort of activities that get taxed at zero percent the risk of a harmful tax competition is in relation to those activities where countries can structure where companies can structure their affairs and shift the activities easily around the globe in order to get themselves the best possible tax arrangement so here i mean we're trying to achieve the right balance making sure that those companies that are generating profits in market jurisdictions but currently are not paying their fair share of tax in those jurisdictions that we very much hone in on to those business activities to make sure that they pay their fair share of tax in those markets where their customers are and where they generate their profits but we don't want to obviously create counterproductive distortions in relation to real activities and substantial activities in economies around the world minister i think that matias rated very very raised a very interesting point and that each country is coming with their own different structural setup the number i think you said was at a proportion of total GDP only five percent of five five and a half percent is coming from tax and african nations in general rely a lot more in corporation tax than on other types of taxes just to give a number that i read in 2017 african countries raised 19 percent of their overall revenue from corporation tax compared with an average of just nine percent for OECD members so are a little bit more reliant on those corporate tax revenues well those those numbers are correct but also we believe if there's a global initiative you should consider different sizes of countries that are on the table um why do we have only the largest mns in under consideration why can't we have another pillar that addresses medium-sized companies which are the majority of the companies that are operating in our jurisdiction so if we sign up to this it means we're excluded from getting taxes from medium-sized companies that we now actually by our own laws have an opportunity to collect taxes from and um and i do understand and appreciate your your situation matires that progress needs to be made and uh we support this initiative we're on the table we're just asking for a reconsideration of some of the commitments that have been made so that we we're not going to end up we're not going to end up if we sign up to this our analysis is we are going to end up with negative tax so taxes that we used to be able to collect from this medium-sized companies we cannot collect the majority of the companies that are in this in this in this rules now are not operating in our jurisdictions so so there's there's a need to reconsider how to make either some amendments or how to add another scope that helps us to capture more of the companies that are operating in developed developing economies like Nigeria is there any overlap between the proposal uh via the UN uh what you're pushing for at the UN level with the existing OECD proposal there it is but the the UN uh proposal is is it's kind of more straightforward and simplistic but the limitation it has is it has to be based on on a bilateral tax treaty so that's a huge limitation we hope also that that can be that can be corrected the complexity like i said earlier on it's also a very important uh consideration one of the reasons why we have a lot of profit shifting and tax evasion in our countries is because of the limitation of skills of trying to identify these practices trying to even implement our own laws so when you are now made to sign or you commit to sign to a process that is complex you're providing more room for those leakages to happen the curve outs i just don't understand why the some of the analysis we made from those curve outs while it is uh reaching as 10 percent could be effectively as low as two to three percent so there's a need for a reconsideration and it's not to say you can't move forward with the first uh uh effort that has been made but there's a need to quickly look at some other additional variations so that countries like us even some of the countries that have signed up to are also now rethinking because when you go to your parliaments these questions will be asked and how do you get this laws passed in your jurisdictions if the analysis shows that you end up with negative revenue inflows as opposed to gains very clear at gibrael i want to go back to something you said earlier which is in general corporate taxes have been dropping since the 80s from about 45 percent to around 20 percent i think now you said what i thought is interesting is uh in the last couple of years more so than ever countries have been focusing a lot more on their own fiscal situation and you can't talk about tax reform without thinking about it through the lens also of the public finances and what uh pressure countries are under to bolster them i thought it was notable that in the uk for example recently they have actually reversed their policy on corporate taxation to corporate tax is set to rise from 19 to 25 percentage point i think only one of of two oecd countries that has announced such measures in recent years do you think this era of the race to the bottom on corporate taxation is coming to an end unfortunately no i really wish uh i could uh have a more optimistic answer but what you have to realize is that with the agreement as it's as it's going to be uh hopefully implemented in in the near future um there is going to be very strong incentives for countries to keep offering low tax rates tax rates even lower than 15 percent to attract activity on their territory it's true that today there's no uh country where a lot of there is a lot of substance meaning there's a lot of production happening with a zero percent tax rate but we might well go there today we have countries where there's you know substantial production happening with rates uh that are below 10 percent especially no tax rates for income derived from intellectual property with all patent boxes you know it's very common to have rates that are five six seven percent that's the situation today and we might even get too too less than that in the future because the agreement doesn't put a floor to to tax rates uh to how low tax rates can go when firms have real activity and so i'm really concerned about that and the reason why i'm concerned more broadly is that you have to take you know the bigger perspective on tax systems the corporate tax is one tax but you know it's not the main source of tax revenues at least in most countries however the reason why it matters a lot is uh because it's essentially impossible to have a progressive individual income tax which is in most countries the pillar you know of tax progressivity the way we attempt to tax high earners it's impossible to have a well functioning individual income tax without a well functioning and high enough corporate tax because if if the corporate tax is if the corporate tax rate is too low then what happens is that rich people incorporate they operate as businesses they earn income you know subject to the corporate income the low corporate income tax rate and the individual income tax unravels and so if we want to do anything seriously to curb the rise of income and wealth inequality it's going to involve progressive taxation progressive taxation of income in particular and that needs to involve substantially higher corporate income tax rates i don't see a future where corporate tax rates remain you know 15 percent or even less than that and we can really tax high income earners at substantially higher rates i think and and so the risk at the end of the day is just to see a continuation of the rise of income and wealth inequality that we've witnessed in recent decades there's an important point here though i mean what we're trying to address with the global tax deal is tax evasion that is facilitated by shifting from country to country i mean the issues that you rise can be addressed now by individual jurisdictions i mean the global tax dealers on the table the you know through the inclusive framework does not prevent countries from imposing higher corporate taxes it's a minimum global tax it does not prevent countries from addressing the risk that you describe of incorporating yourself in order to avoid higher progressive personal income taxes i mean there's all things that individual jurisdictions can address for themselves subject to their democratic processes the reason why there is a need for an international agreement to address what we're seeking to address is because of the capacity for big multinational businesses to shift their affairs into structure their affairs such to essentially pick the jurisdiction that gives them the best deal and then in the sort of whole process also i guess provide you know put pressure on some countries to offer deals that quite frankly are tax wise for so i mean i i don't think that the deal that is on the table would prevent individual countries from doing what you're suggesting if that is what they choose respectfully i disagree with that because if there's no limit to tax competition it's very hard for individual countries to increase their corporate income tax rate if firms can move their factories can move their headquarters can move their employment to low tax countries where they will still be subject to tax rates below 15 percent so i'm sorry but this agreement doesn't help countries to increase their corporate income tax rate unfortunately well substantive activity is not shifted no but that's that's the same problem it's even worse you know shifting paper profits across countries no pure profit shifting i agree with you is going to be very substantially reduced thanks to pillar two and i started my remarks by saying that it's a you know very important progress and it's worth celebrating progress when it happens so pure profit shifting booking billions of dollars in profits in territories where there is no activity this will come to an end those profits will be taxed at at least 15 percent and that's you know that's a very good development however what is not going to change what what's not going to change is that there will remain incentives for firms to move not their paper profits but their factories their workers their headquarters their real activity to very low tax countries including zero tax it's going to be difficult that's an even bigger problem that's an even bigger problem it's going to be difficult to come up with a solution on this panel but also a solution one solution that works from the very first draft and this is the first draft of serious international tax reform and as all of you have said it is a step in the right direction but there are a few lingering issues face all i'd like to sort of round up the discussion with you Saudi Arabia is in actually in a in a special situation contrary to what Gabrielle just described because there's no income tax but there is a high corporation tax corporation tax is about 20 i think and Saudi Arabia but of course no no income tax how do you think about tax as as a tool maybe a blunt tool in terms of wealth distribution so i think we have to keep in mind that Saudi managed to increase VAT from 5 percent to 15 percent during one of the most challenging times and and according to Kristalina yesterday on the Saudi panel it's virtually the only country that was able to do that successfully so we look at simplifying tax revenues and utilizing them in a way that was never done before but not at the expense of economic growth or economic development so Saudi has been a supporter of of this pillar one and pillar two from the beginning during the G20 presidency led by Saudi Arabia it was pushed all the way to paving the way for it to be announced during the Italian presidency i think there are challenges one we need to as we said listen to all constituents and leverage multilateral platforms to enhance the institutional capabilities of all governments all players all partners i think with better institutional capability we can shift the focus from minimizing the change or minimizing the impact to where else can we compete and i think the ultimate long-term effect of all of this is that we will look at competitiveness and fundamentals that will help our economies become more sustainable rather than rely on fiscal incentives that will probably take us nowhere there's another thing that's challenging in this and we still think sticking to the frame time frame is important is it's it's complexity this is very complex and it takes time for everyone to understand it including governments and to understand where they will how they will be impacted where and to what end and ultimately there are always options but if you extend the investment horizon a little bit and think more long-term i think it and couple that with raising institutional capabilities everywhere we can think more broadly about what these can push us to do but it's very complex i'm pretty sure if we go to chat gbt we'll get no answer one thing they don't have an answer to the other thing just one last point i think companies say their admin costs related to it but the structures will shift and will become a little more logical with minimal distortions it'll cost us a lot to get there but a steady state i think it's more logical well we've got about six minutes i want to see if anyone in the audience would like to ask our panelists a question i'm going to open it up yes name is david bucking i'm a journalist with deschbegel in germany um text consultants have historically been really good in finding the loopholes in new legislation how confident are the panelists that this will not happen with this new agreement especially in developing countries that the tax administrations there have enough resources to actually enforce these rules well i mean a big focus of our work is on supporting capacity development in developing economies i mean it is a real issue there's a real challenge there and and that is also why we're having conversations for example in relation to the transfer pricing provisions on simplified arrangements i mean it is a challenge it's something that we've we've got to make sure that we continue to work through but i mean we do believe that this is a robust deal i mean it is you know in the end if you want to get consensus among 140 odd countries you have to get a lot of different perspectives onto one table and you know in the end we can say i say it again i'm repeating myself we can say well let's hold out for the perfect where we have got no risk and no issues and but it doesn't happen or we can go ahead with what is in my opinion the best viable deal on the table right now make it work deliver the additional income in particular to low income and middle income countries so that i can invest those resources into economies and into their communities but but of course i mean you know this is to to implement this effectively will take a lot of work and there is you know in particular a lot of work to be done on capacity development in developing countries do we have another question would you like to take a crack at that yeah add to that that i'm actually pretty concerned about this happening because it has happened in the past so when uh harmonized transfer pricing regulations were introduced you know in a number of we cd countries we saw that this was a boon you know for the transfer pricing industry we saw an explosion you know of activity in the transfer pricing industry to find loopholes and very little or sometimes no positive effect on tax revenues and this is a very very complex agreement and i'm very concerned that this might play out again in the future i would just like to add something that you know relates to the need for unanimity or consensus all of these discussions start from the premise that we need to have all countries and territories on board we have to question that because if we have that approach in effect it gives a veto power to countries and territories that benefit enormously from the status quo that benefit from profit shifting that benefit from tax competition and that's how at the end of the day you have significant loopholes and cabots that are introduced with in the agreements and so there are other ways to proceed so for instance when we look at what happened for bank secrecy there used to be a strict bank secrecy in countries like switzerland in other tax havens but this changed not because of a you know consensus it changed first and foremost because of the united states because of unilateral action by the united states you know in 2010 with the foreign account tax compliance act that threatens with banks with economic sanctions and under those threats the banks agreed to cooperate with the us and that it paved the way for a multilateral agreement but historically progress often happens like that there is unilateral action could be one country could be a group of countries showing that we can do better better than 15 percent could be 25 percent minimum tax rate and then it creates a dynamic for ambitious global agreement we've got about two minutes left matias i just want you to spell out to the room what you think is at stake if this agreement does not get implemented well what is at stake is about 220 billion dollars in additional revenue that's on the table from pillar one that would benefit all countries but in particular except for investment hubs who lose tax bias and and and tax revenues but which would in particular benefit low-income countries what is at stake is of you know the implementation of reform agreement that would make our international tax arrangements fairer and work better will everybody unanimously say this is the perfect thing and the best thing since sliced bread no but is it better than what we currently have substantially better yes should we give i mean i would just urge everyone not to give up on this not to give away this chance to substantially inform to substantially reform the international tax arrangements to make them fairer and work better for the 21st century final word for the minister well i just want to appeal to OECD to also make sure that as you're seeking this tax reform which we agree with that you're not leaving some countries worse off than they already are or completely leaving out some some countries in the bargain because i believe with just a little more effort there can be a way to accommodate some of the concerns that the african countries have so it wasn't just nigera it was a meeting of african countries that agreed for nigera to submit on behalf of african countries the concerns that we have so it was it wasn't just nigera well look i'm going to end this by saying at least we're sitting here and having this discussion and that is a step in the positive direction thank you very much thank you