 The kind of challenges that developing countries face in generating revenue or collecting revenue from multinationals operating in their countries, we want to have a quick look at the BEPS process to see whether or not that process is positioned to address some of those concerns and finally I want to place it in an Irish context and see what if any role Ireland can play in ensuring that some of these things that would make a difference to developing countries can be an Ireland player role in that. So in 2011 a leaked audit report from the auditor's Grant Thornton highlighted that the Mopani mine which is a subsidiary of the Commodities giant Glencore was undervaluing their sale of copper out of Zambia to sister companies in Switzerland and exaggerating the costs of their labor costs in Zambia in an effort to minimize their tax bill in Zambia. To quote from the leaked audit report it said we believe that the Mopani cost structure cannot be trusted to represent the true natures of the costs of the Mopani mining operation and it requires more follow-up. Based on the two years for which the company was audited the Center for Trade and Policy and Development in Zambia estimate that Zambia lost out an 88 million euro in taxable revenue. The Zambian government themselves estimate that they lose on an annual basis two billion dollars every year to transfer pricing abuse in the main from the mining sector. This is in a country where life expectancy is 47 years. In 2013 the NGO Action Aid published a report entitled sweet nothings in which they detailed the elaborate tax avoidance scheme of ABF sugar UK food conglomerate which resulted in 17.7 million since 2007 to 2013 been lost to the Zambian exchequer. What's interesting from an Irish perspective is that part of that scheme involved the use of subsidiary company based in the IFSC which was charging for management and purchasing costs from their subsidiary company in Zambia on an average of 2.6 million years since 2007. It was taking advantage of the Zambia Ireland tax agreement which doesn't require withholding tax on purchasing and management fees coming out of Zambia. I should say that the subsidiary in the IFSC has zero employees. In 2014 Christian Aid and its partners in Sierra Leone produced a report entitled losing out and it highlights that the cost of tax expenditures incentives and exemptions granted to the multinational operating in Sierra Leone costs more than eight times the health budget and seven times the education budget. This is in a country where 50% of the population live below the poverty line. I give these examples by way of providing three distinct and different examples of the challenges that developing countries are facing. First is illegal it's an abuse of the arm's length principle and nobody should have any struck with that. The second is legal but it's an example how the system in its current format is being abused and milked by legal tax avoidance schemes. The third is an example of the pressure that resource rich capital poor developing countries are placed under to attract foreign direct investment into their countries while avoiding well trying to avoid a dangerous and damaging race to the bottom with their neighbors. There's lots of numbers bandied around around the extent and the volume of revenue lost to developing countries. They're all contested it's like trying to put a number on the drugs trade. What we do know though is and what the OECD agree with is that they are losing more money than they're receiving an aid on an annual basis. The question is can the OECD BEPS process address these issues and will it make it more easy or easier for the for developing countries to generate and collect revenue. The answer is probably not. There are real questions about the ability of the OECD to deliver reform equally for all countries. Fundamentally the OECD BEPS process is not set up to represent all countries equally. The OECD is as a membership of 34 of the wealthiest countries in the world and the BEPS process was designed for and by these 34 member countries plus the non OECD G20 countries and not with developing countries in mind. These sentiments are captured by Francophone finance ministers in a statement in Washington last year where essentially they say that the low income countries need an equal place at the decision making table. There have been plans for greater consultation from the OECD announced last month which are very welcome but fundamentally it's as much an acknowledgement that the process up until now has been fundamentally flawed at least from the perspective of developing countries. Inviting some developing countries into a process that is progressing I think it's agreed at a remarkable pace and to expect them to work to an action plan that has already been agreed will not get to the core of the problem of a lack of representivity inclusivity and participation. Christian Aid published a report recently highlighting these and other concerns and just to take two points from the action plan to highlight the fact that most of the issues that are relevance or of interest or value to developing countries have been de-prioritized and those that are of most interest and value to OECD countries are the ones that are getting most attention. Action point five to give an example commits the OECD to tackle harmful tax practices. This as illustrated by the Sierra Leone case has the potential has huge potential for developing countries if real action was taken on it was taken on it. However progress on this including progress on this has been blocked or has been very slow including blocked by some OECD members ensuring that little or no progress has been made on it. Action point 13 will require as we heard Pascal say this morning companies to report on a country by country basis this would provide the kind of information that people will need to be able to identify whether or not the economic presence of a company corresponds to the tax that they're paying. Again this would have been very useful in the Mopani mine case it would have held up a red flag very quickly that there's something irregular was going on. However the OECD doesn't propose that this will be placed in the public domain. In fact it looks increasingly likely that it will not be made available to developing country revenue authorities. We heard Pascal this morning say that these will be exchanged on a tax treaty basis. Well that's very unfortunate for developing countries who don't have tax treaties in the main with Switzerland or with Luxembourg or these countries where there is much less access to the information that they would require. Finally it's it's essentially a question of democracy. It has been said by by many including Pascal that the legitimacy of the OECD bets process lies in the fact that it represents 90% of the world economy. This may indeed provide it with an economic mandate but with over 100 countries not involved in the process it does not provide it with a democratic mandate. But I don't want to be too um unconstructive in my comments and I do have four quick things that I'd like to propose that could improve the situation of the BEPS process going forward. One more effective and real engagement with developing country governments and civil society. A focus two a focus on priority sectors for developing countries. The extractive sector, agriculture and a stronger focus on the specific needs and approaches that would help developing countries tackle transfer pricing abuse. The third G20 countries could provide a statement committing them to ending the beggar thy neighbor policies of tax practices which only result in a dangerous race to the bottom. A race to the bottom that Christine Lagarde has said just leaves everybody sitting on the bottom. And finally the process should take place within an intergovernmental body which is fully representative and fully inclusive. To conclude with to place this in an Irish context the Irish government is very much involved as one might expect in the BEPS process and there are two documents that should in part be guiding their engagement with the BEPS process. The first is the Ireland's international tax strategy from the Department of Finance of 2014 in which it makes a commitment to ensure that developing countries are able to raise their own revenue. The second document is that from One World One Future which is a government document which lays out Ireland's international development strategy in that there is a commitment to ensuring greater coherence across policy across government policy including in the area of tax and development. But it is precisely in the area of tax and development that some will see a contradiction between on the one hand a commitment to ensuring that the reforms within the international taxation system has been led by the OCD BEPS process ensuring that that benefits developing countries and on the other a commitment to what some will see as the harmful tax practices that form an essential and central part of Irish foreign direct investment policy. That Ireland has launched a spillover analysis of its tax work of its tax policy to see whether or not there is any negative impact on developing countries is extremely welcome and whatever the findings are when they emerge by the end of this year it would seem clear that there will remain attention between ensuring Ireland is able to thrive under whichever new international tax regime emerges and providing the same opportunities for others to develop and not condemning those countries to a continued reliance on aid. I'd like to conclude by thanking the Institute for inviting me to speak today and for giving civil society an opportunity to be present at this important event. Thank you.