 The world of international taxation is changing rapidly. We are now living in a time when tax no longer is relegated to just the business pages. It is now front page news where multinationals tax affairs are scrutinized and where each country's taxation regime is analyzed in detail. In short, tax is no longer a minority sport. It is for this reason that conferences such as today's event are so important as they provide an excellent form for exchanging views between stakeholders and policymakers. For my part today I would like to take a few minutes to discuss where I see the world of international tax agent today, the OECD BEPS project and the current state aid investigations being undertaken by the European Union. In an increasingly globalized world, the differences in tax laws between countries have inevitably led to mismatches which can be exploited by corporations with an ever increasing global footprint. The way in which countries choose to tax their resident companies will inevitably impact on competitiveness. In a global setting, the rules regarding the taxation of foreign subsidiaries can be a significant factor in competitiveness abroad. It is the differential between these rules in the US in relation to taxation deferral and those in place in some of Europeans' biggest economies that have led to some tension in the international tax area. It is no coincidence that the majority of EU state aid investigations that are taken from a taxation perspective have been directed at US multinationals. While I would not like to go into the specifics of this debate, I think it explains why we in Ireland as a mid-Atlantic economy are sometimes caught in the crossfire. That said, in my view, it is not right or fair that only US companies are included in the international debate on the appropriateness of global tax laws. All countries and all companies throughout the world should have a stake in ensuring that international tax rules are fit for purpose. In Ireland, we like many others have made mistakes in the design of our domestic taxation system in the past. And these mistakes are the mistakes we must learn from as we prepare for the future. We have, I hope, learned lessons from the property-based tax reliefs that were allowed to continue for too long with no clear rationale behind their maintenance. Lessons such as these must be applied domestically in designing the Irish tax code for the future. In this regard and budget date, I published new guidelines for the evaluation of tax expenditures. And these have now been sent to all secretaries general in all relevant government departments. But the lessons learned must also be borne in mind when determining our international tax strategy. The so-called double-lyrish tax regime was never part of Ireland's tax code. What's more, it was not a sustainable way to build a thriving foreign direct investment sector for the long term. As we have learned from the past, any regime that is built on unsure foundations will ultimately be shown to be not fit for purpose. It was for this reason that I made changes in our company residence rules and the recent budget. These changes have further enhanced both the tax reputation of our country and the reputation of those companies that wish to do business here in Ireland. You will have noted that the main industry bodies welcome the changes as they give certainty to investors over the medium term. And having held discussions with numerous stakeholders down through the years, I'm more than aware of how important certainty is in international business. However, what I have consistently stated from a tax policy perspective is that Ireland will play fair, but will also play to win. This belief led me to make a number of enhancements to our tax regime to best position that regime for a post-BEPs era. These changes announced on budget day were accompanied by a new roadmap for Ireland's tax competitiveness. The roadmap updates last year's international tax strategy and contains a comprehensive package of competitive tax measures which will provide the foundation for Ireland to maintain and expand our position as a thriving hub for foreign direct investment well into the future. The enhancement includes changes to the R&D tax credit, expansion of our intangible assets, amortization provisions, broadening of the special assigned e-relief program, and increased resources for the revenue commissioners competent authority function. The last of which we feel will become increasingly important in a post-BEPs world. I've also signaled my intention to introduce a knowledge development box in budget 216. However, as I stated, it will be necessary to ensure that such a regime meets with the standards to be agreed both by the European Union and the OECD-BEPs process. I welcome the role that the International Consortium of Investigative Journalists have played in uncovering the information behind the recent Luxembourg tax leak stories. Ireland's 12.5% rate is one of the lowest in the OECD. And we do not hide it. In fact, we broadcast this rate as the defining element of our corporate tax system. The Irish regime is fully transparent as our rules are clearly laid down in statute. We've a proven tax record of supporting transparency. As we are early adopters of automatic exchange of information, we were the fourth country to sign up to FATCA and our vocal supporters of the common reporting standard. Furthermore, I note that a recent independent report carried out by PWC and the World Bank has designated Ireland as having the most efficient corporate tax system in Europe. Some newspapers this morning outlined the details of a letter that was sent by the Finance Ministers of Germany, France and Italy to the European Commission, urging that certain actions be taken to counter aggressive tax planning in the European Union. The French Finance Minister, Michel Sopin, was in Dublin last Friday and I discussed this letter with him and I informed him that Ireland welcomes it as a positive contribution to the wider ongoing international debate regarding and how best to tackle aggressive tax planning. Ireland supports all moves to increase tax transparency. As outlined in our roadmap for tax competitiveness, Ireland is maintaining its commitment to ensuring an open and transparent tax regime. The main thrust of the letter I mentioned is the call for an EU directive that will counter aggressive tax planning in the European Union. Such a directive will take some time to design, to discuss and to develop and of course tax remains a matter for unanimity at European Union level. However Ireland will contribute constructively to these discussions in the EU as it always does while simultaneously holding a forum line that matters on direct taxation remain a member states competence. Ireland is fully supportive of the OECD BEPS project and is actively involved at all levels of the discussion. The work that has been undertaken is unprecedented and I would like to congratulate Pascal Sannemann on so far delivering and what are very ambitious time frames. Furthermore the quality of the output to date is a credit to all the countries involved and also to the OECD secretariat for their tireless work. The goals of the project as I see them are twofold. The first goal is to eradicate double non-taxation and the second is to ensure that there is better alignment between substance and taxing rights. These goals are critically important and they are aligned with Ireland's international tax strategy. While I remain overwhelmingly positive about the OECD BEPS project there are inevitably a couple of concerns that I have with the BEPS process and I will discuss them in turn. My first concern is the depth that BEPS must not be about advantaging big countries over small countries and equally must not be used to single out US multinational entities. If BEPS took this course it would merely be playing to the gallery and not be focused on real tax reform. It is agreed that the BEPS process must strive to provide a level playing field for all but it must not become a tool used to increase the comparative competitiveness of larger nations at the expense of small countries. On this level playing field small countries must also be able to play fairly but to play to win as we in Ireland have always tried to do. As I mentioned I am opening a consultation on the Knowledge Development box before the end of the year and the recent joint announcement by the UK and Germany brings the design of such a box into focus. The UK-German proposal calls for a modified nexus approach towards demanding whether the activity in such a box would be deemed to be substantial and therefore not considered a harmful regime. In a nutshell it appears to me that the determining factor will be based upon whether any given entity looking to access the benefits of the box meets the required percentage of total research and development workforce in the group as a whole. This approach on the one hand fits within Ireland's core value of attracting substance, substance-based investment. However on the other hand I do have concerns that such an approach if designed too tightly could have the potential to limit the scope for use by some smaller countries. Would this represent a fair reform? I don't think so. For the discussion is both planned and necessary in this area and I would encourage stakeholders to join the debate either through our public consultation process or through the many avenues open at OECD level. My other concern in relation to the BEBS process is that it cannot just be a dialogue of the privileged. It would be a missed opportunity and morally careless if we let the excellent work being undertaken by the OECD to not be heard in the developing world. In Ireland we are coming towards the end of our spillover analysis which I will be publishing in the coming months and which will highlight how our tax system impacts with the developing world. We believe that such research is critically important to ensure that the playing field that I have mentioned is both level and open to all. I am aware that the OECD are actively trying to involve the developing world in the current discussions. However I think that in order to show full commitment and foster a trusting relationship between the developed and developing world the OECD should adapt at least in spirit a 16 action in the BEBS project that insists upon all countries undertaking spillover analysis and how their taxation regimes impact on the third world countries of the developing world. I would like to take this opportunity to also welcome the recent comments of EU Commissioner Vestiger in which she stated that the current state aid investigations would reach conclusion by the middle of next year. In relation to the one case in which Ireland is involved while for legal reasons I am unable to discuss any specifics my advice is that the case against us is weak and therefore I think that an early resolution would be in the best interest of everybody. As I have stated before in the unlikely event that the European Commission does find against Ireland in this matter we will use every legal avenue open to defend our position. I don't say that in any challenging way. Margarita Vestiger was Danish finance minister for the last three years I met her every month and she has been supportive of Ireland's position as I have been supportive of issues that Denmark wished to raise. So I will be discussing these issues very shortly with her. In conclusion to summarize the number of different aspects of my speech today I would remind everybody of the importance of evidence-based policymaking the increasing requirement for international cooperation to see a just and equitable course towards international tax reform to learn from the lessons of the past and finally the critical need to consider our impact on the developing world. Thank you very much indeed.