Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation - Second Substantive Session 2025, 2nd meeting

Good afternoon everyone. I hope you enjoyed your lunch break. I think we are ready to start now and resume our discussion. So now we are actually resuming the floor from the first session. So we finished last session with a pending list for some speakers. So Now we're going to start back again. So I give the floor to the distinguished delegate of Nigeria.

Thanks, Chair, and welcome back from lunch. I know that lunchtime may not be a good time for some meetings, but hopefully not the kinds of meeting where we have very interactive discussions. I appreciate the co-leads. and all the delegates that attended WOTSTREAM II for putting the issue notes together. It has been a very good document at least to start with. I also wish to thank the distinguished delegates of Kenya and ATAF for the presentations that they have made on behalf of the African group. Nigeria participated in the work stream two discussions and we had submitted our written comments so I don't want I do not want to go and read over what we had submitted at this plenary but riding on what and the African group has submitted I wish to further stress on certain aspects of the submission no doubt considering the scope of the protocol We have said that it should cover a wide range of issues of services, including digital services, and also a margin one. And I hear even people speak delegates speaking in the room also alluding to that. And this we need to do without requiring the establishment of a permanent establishment. If we still want to be hindering all our rules on permanent establishment, it therefore means that we are yet to leave out the rules that are not effective for the current way businesses have been done. So the protocols, we put it on the table that it should be designed in a manner that governments are able to tax or collect taxes when there is value creation, when revenue have been delivered from, derived from such traditions and when activity has occurred. That is the spirit of the UGA resolution 78 to 30. And until we are able to do this, we cannot say that taxation rights have been fairly allocated between the source and the resident jurisdictions. What is fear is fear. It has no other name. So that is our position because it is disheartening when you see activity in your jurisdictions, you see revenue have been generated, but you are not able to tax to collect the much needed tax that you require for development. It is not pleasant at all. for developing countries, including Nigeria. So Nigeria will support and propose the adoption of simplified and flexible nexus rules, including those that could be modeled around the significant economic presence or payment-based sourcing rules similar to what we have in the former Article 12A of the UN Model Tax Convention or some other kinds of categorized sourcing rules like we have under the arm's length. Gross basis taxation, we support that and we put it on the table and I've also had distinguished delegates put that on the table during the morning session. You know, we believe that gross basis taxation could be adopted. All we need to do is to ensure that the rate is realistic and is a good proxy of the net taxation that I know that some jurisdiction will prefer. So it's also possible to allow the non-resident enterprise to file returns, you know, instead of, um, uh, if they, if they do provide the next basis taxation and when such information or such returns are presented in the source stage, it gives further information to the revenue administration to be able to evaluate it and see if that will be, will fit for purpose. So, We have said repeatedly that we support approaches that provide simplicity and equitable alternative, which is part of the examples that were provided. The complex system, no doubt, is a challenge not only to Africans, but to developing countries and even to developed countries in most instances. Transfer pricing rules are very complex, not only in theory, but in practice. And if we know that they are complex, then we must therefore seek for a workable alternative. I also speak about the type of tax. What we think is the tax must not be the one that you can easily shift the burden to the taxpayers. because we are shifting the burden to the taxpayers. You are therefore indirectly you are taxing your national or your residents. You are not taxing the service provider. So we support inclusions of provisions that also will make possible the prevention of tax avoidance and eliminates double taxation. You know, Chair, you see, when you see something, they say you say it, then you sort it. We are foreseeing these problems. We are seeing it now. The next thing is just to sort it out and put it at the back of our force so that we can move forward. I thank you, Chair.

Thank you. Distinguished delegate of Ghana.

Thank you, Chair, and good afternoon, colleagues. Chair, there is a saying, "In things fall apart, by Chinua Achebe, which I think very much resonates with us. And it says, "A naked bird says that since men have learned to shoot without missing, he has learned to fly without perching." Now, the issue here is that the bird, the hunter has learned not just to shoot without missing, he has learned to shoot without aiming. And in these days of AI, it's possible at a point in time, all he has to do is to think of shooting and then the gun will go off even without a gun. And so we've talked about having some rules that are future proof. And that's where I want to lay the emphasis. We've said it as the Africa group, my colleagues in Nigeria, ATAF in Kenya have mentioned it. And we really want to emphasize that we need to have rules that are flexible and adaptable to whichever service area we are looking at. And believe that once we have these rules that are open enough, it will allow us to end and make up the revenue that we need to make have it allocated fairly since this translates for some of us in the developing world not just into revenue for its sake but it means a child can go to school it means someone can get medical services which are basic needs of everyone And in so doing, we also wish to suggest that, and we've made, the statement has been made, that it's important to have some form of instrument as soon as we agree this that would fast track implementation so that there are no, should I say, barriers that are put because of treaties that pre-exist or some of the agreements that have been made, and everyone will get the opportunity to move and get the revenue that they need. And basically, this is what we will see for the interim. I'm sure maybe the opportunity comes later on, what something. Thank you.

Thank you. Distinguished delegate of Netherlands.

Thank you, Chair, and thanks to the co-leads and the secretariat for preparing this draft issues note. We also thank the other distinguished delegates who participated in the work streams for the fruitful discussions we had in the work stream meetings. We would like to respond to the question raised by the co-leads to the Intergovernmental Negotiating Committee as to whether there is anything missing in the issues note. We will not repeat all our written comments, but we believe that, since we are discussing the allocation of taxing rights related to business profits, there would be merit in explaining in the issues note the reasons behind the distinction between income from services and income from the sale of goods, as changing business models affect the provision of services as well as the sale of goods. We believe this could be better reflected in the issues note. Additionally, we support other distinguished delegates before us who mentioned that the development of this protocol would benefit from analysis of the issues and on the impact of any possible provisions discussed. In our view, some analysis to this end may already be included in the issues note. Thank you, Chair.

Thank you. Distinguished delegate of the United Arab Emirates.

Thank you. We begin by firstly thanking the Chair, the Secretariat and the co-leads for all their efforts and work that has gone into this workstream. We especially recognize the complexity of the issue under consideration, particularly with regards to how such potential new taxing rights do overlap or can overlap with existing treaties and established tax principles. Whilst we understand the need to consider the taxation of services given new business models, and of course that has already been stated many times, some that don't require physical presence. We are however concerned that the current scope of the workstream risks oversimplifying and understating the role of value creation and substance. In particular, we see the lack of references to concepts such as significant people functions or key entrepreneurial risk taking functions as concerning. We are also concerned that the discussions regarding digital services tax is now being mixed with a broader dissatisfaction of the taxation of general services. And such a generalization in our view risks creating a solution which fails to recognize the unique functional characteristics of various services and their providers. While some delegates have suggested that different tax rates could potentially be applied to different services, we again think a rate discussion alone neglects the underlying economic characteristics of different services and their nature. And this inevitably will introduce ambiguity and uncertainty when trying to define different services. The discussion of taxation on a gross basis, in our view, is simply likely to increase the cost of that service, which is typically borne by the end customer, or in this case, the residents of state S, thus making access to that service even more restrictive for such taxpayer or residents. Again, in our view, such actions will not help, but in fact hinder cross-border trade and finance, and therefore we recommend a more balanced approach that considers alternative solutions drawing from existing and well-established transfer pricing principles is considered. We think that these are both obviously familiar with governments and the business community as well. From our perspective, this can include, but is not limited to, for example, the recognition of services PE or a reduced time threshold, for example, for a service PE or the use of existing articles in many double taxation agreements, such as director fees or other income, where such matters are negotiated between two jurisdictions or more. Thank you very much.

Thank you, distinguished delegate of Saudi Arabia.

Thank you, Chair, and the co-leads and the Secretariat for the extensive efforts. When it comes to the issue note, we believe it's a strong starting point and will certainly help to encourage a constructive discussion. However, if we are going to cluster the issue we have when it comes to cross-border taxation, they would fall in one of the two categories. The first is the case where a tax treaty limits the taxing right of a jurisdiction, and the second where there is no practical enforcement mechanism that can be developed under the most legal to tax. For example, a case where a payment is made from country A to country B in order to show advertisement in country C. Therefore, our objective should not be to overhaul the entire international tax framework, but rather to focus on addressing the situation where existing rules no longer work. As digitalization advances, the need to develop new rules becomes more pressing. While the concept of physical presence continues to be relevant for certain business models, we do not believe it is suitable for all models. and more modern approaches are required to keep pace with the evolving business development. Finally, on the matter of net versus gross based taxation, we should explore both options in depth. As you know, net based taxation align more closely with the traditional principles of taxing profit and may be perceived as fairer, but it can be more complex to administer, especially across jurisdiction with varying rules and profit attribution methods. While on the other hand, gross-based taxation offers simplicity, uncertainty and revenue collection, but may be seen as less equitable, particularly for low margin businesses. A balanced assessment of both is needed in order to ensure that what we are going to develop is feasible from administrative point of view. Thank you.

Thank you. The Senegal.

Thank you, Chair. I'd like to begin by aligning myself with these statements made by Kenya and Nigeria on behalf of the African group. I also would like to have some clarifications because in the discussions, the co-chair had spoken about a technical debate on the examples that were displayed, but I realized that instead of responding to the technical presentation, we continued to make statements. And the problem that we are addressing are technical problems. with divergent positions. So I think it's important to begin this technical debate so that we can better understand what needs to be done and to define what steps need to be taken. As the African group has stated, we need to have a broad scope. But when we hear the different positions, we also realize that there could be different categories here, traditional services, that require physical presence and stable establishments, tax conventions that differentiate different modalities, but also new services, especially digital services that don't require physical presence, but that require other kinds of regulations. So these are two well-defined categories. Now, what does not fall into the first category, we have to define that. If we define what does not fall into the first category, then how can we address that so we can tackle the challenges of inclusiveness and equity, which we have underscored since the beginning of our discussions, which have already led to the addition of 230. Now, if we define these elements, what kind of mechanism can we establish to resolve these issues through a multilateral instrument? So I think that we need to have this pragmatic approach to be able to make progress if you want to stop discussing the same topic over and over without ending up with a real convention. If you take a look at digital services, for example, if we don't have multilateral instrument, then we'll have unilateral solutions. Of course, it's better to have a multilateral solution. that should be the foundation of our negotiations to find appropriate solutions guaranteeing equity and guaranteeing tax certainty. The other point that I wanted to emphasize that some people have mentioned why shouldn't we not tax goods but of course we have to base ourselves on resolution 08230 we're not talking about goods we're talking about taxing services. Lastly We've spoken about certain in-depth technical elements. To better define these technical elements, we have to first agree on the scope. And when we agree on that, after that we can go more in depth on these technical elements. So we need more clarity, articulation in order to have a clear vision so that we can define a protocol that can address our respective expectations. Thank you.

Thank you. Distinguished delegate of Canada.

Thank you, Mr Chair. I would just want to intervene to make a few general comments in the line of the comments that were made by the distinguished delegate from Senegal. as to how we should try to answer these questions and move the work of the committee forward. I think we see the questions that are in front of us as no different from the other questions about how we should design international tax rules. So we certainly agree that we need to look not only at fairness, but at the other normative objectives that are commonly referred to in international taxation, including economic efficiency, including the ease of administration and the robustness to tax avoidance. That said, there is two key questions here. The first one is how we should be taxing cross-border services, and the second one is who should have the taxing right in that respect. And I don't think we can dissociate these two questions in my view, uh, the answer to, to, uh, to these two questions are related so that we should consider both at the same time. So that means that it's crucial to consider what form of taxation we think would be appropriate for cross-border services, whether it's on a net basis, on a gross basis, or withholding tax, or some other form of taxation, including consumption taxes, because they do affect services. And in that respect, we believe that it would be important to put greater emphasis on the economic impact of the different approaches that we may consider in terms of taxing cross-border services. In particular, we are of the view that there are significant concerns with gross basis taxation and we, for that reason, do not favour gross basis taxation. We think a better approach would be to continue with taxing net profits. The key consideration here, I think, is tax incidence. We agree with some previous comments to the fact that the gross-based tax are very likely to be shifted to the consumers. And to the extent they are, such a tax would not be achieving the fairness or the revenue objective that would justify, motivate this tax. So I think that's one key question on which the committee should take some time to reflect. And these questions are very specific and at the same time I think they call for more hard data, for some evidence. I know we can discuss these questions in the abstract, but it would be very useful if we can get some hard evidence or if we can find studies that would speak to the incidence of the various approach we're considering to, that could shed some, that could provide some information as to the revenue potential of the various options, comparing one option to another, but maybe also other options that could be considered to promote greater domestic resource mobilization. and also some evidence as to what would be the efficiency cost of the various approaches. So I think that would be very useful information if the committee can get that type of information that would help steer the discussions in the right directions and maybe make our discussion a bit more productive. Thank you.

Thank you. Thank you, Director of Colombia.

Thank you, Chair. If there is no physical presence in the country of origin, you need to keep in mind the capacity for taxing these services in the country of origin. The goal in the case of this Protocol 1 is to guarantee equitable taxation. There are a number of examples that have been presented, a presentation of the co-facilitator, especially I think we need to look at the gross base of income generated in these cross-border services. In the example that was given, the country of origin was Colombia. If this was, for example, a social media ad, then we would have to use the rule on links. So there would be taxation of the gross revenue for sales of digital services when the amount exceeds a certain threshold. There also has to be a multilateral agreement in the convention to modify parts of existing treaties, certain provisions, and this has to apply to digital services. We need to fight double taxation in the country of residence. We believe the net-based approach is quite difficult. There needs to already be exchanges of information with the other jurisdictions, which goes against the principle of simplicity. In addition, the scope of the protocol should not be limited to income tax. We should think about the nature of the different taxes. I'm speaking about paragraph 20 in the issues note.

Thank you. The distinguished delegate of Jamaica.

Thank you very much, Chair. And I had omitted to congratulate Lisa Lot and the secretariat. This is not an easy topic to deal with. And I just want to congratulate them on the work that has been done so far. Chair, I am going to reflect on the question, the first question that was asked earlier from the issues note, the second part of it on whether there are additional considerations that should be taken into account in the work streams discussions. And in that regard, Chair, I wish to concur with Senegal and Canada on the issue of economic impact analysis. Drawing on experience from the inclusive framework, economic impact analysis was one of the areas that developing countries called for in the various solutions that were being devised. And it is also an important aspect of how you sell to your political masters, the work that they spend a lot of money to send you to do. And so I think that at some point, Chair, we will have to address the impact analysis of the various solutions that arise out of this particular work stream and we don't have a lot of time, given the fact that February we would have done a year of the three years that we have projected that the framework convention will stand up over time, will be established. And so that is my response to that. I think, Chair, that we can draw, there's a lot of work that has been done on this area. The UN has 12B, 12AA, the OECD work on the two pillars, the DSTs that have been in place. And I think that we can draw on those on those pieces of work and the information that comes out of those pieces of work in putting together the analysis, Chair. The other issue that I want to raise, and it's not a popular one, but I'm going to raise it anyway, and it is this. I'm reflecting on Daniel's point about mobilization, domestic resource mobilization. And I think that ultimately that is the aim of what it is that we are trying to do through this convention. And I wonder why the workstream did not consider discussing digital sales tax or a value added tax as it relates to digital services, given the fact That for most countries, particularly for developing countries, it is value added tax that forms the major part of tax to GDP. And if you are talking about, um, children in school and water and just all the other attendant, um, uh, uh, uh, uh, uh, uh, uh, uh, services that a state is supposed to provide for its citizens and the revenue that they need to rely on. I think that we may be doing ourselves a disservice if in this revolutionary course that we are on, we neglect to provide guidance on the use of, particularly for countries who do not have income tax and do not have treaties and so on, guidance on how they can optimize their value-added tax systems towards digitalization. Thank you, Chair.

Thank you, Jamaica. And perhaps just a short comment on that last issue. I don't think we have decided not to. We are in the scoping mode. So, you know, this is the issues note. And so your point is very well taken, Jamaica, that is extremely important. Again, you know, we have on the slide here taxes covered. That's what we need to hear here today, what sort of type of taxes we're going to cover in the future work. So thank you for that, Marlene. I have no other Sorry, Algeria. Please go ahead.

Mr. Chair, distinguished delegates, good afternoon. I'm taking the floor to comment on what some delegation in this room have said regarding the use

of transfer pricing for the taxation of services. While transfer pricing methods may be relevant in certain contexts, their application to the taxation of cross-border services which creates significant challenges for the tax administration of developing countries. Many of our administrations face acute limitation in resources, specialized expertise, and crucially access to reliable and comparable data. In practice, transfer pricing rules are complex and resource intensive, often requiring sophisticated audits, benchmarking studies, and dispute resolution mechanism that may be beyond the current capacities of developing countries. In this regard, we wish to underscore the importance of developing alternative approaches that are simple, clear and easy to administer while ensuring fairness and predictability for those taxpayers and tax administrations. Such rules would allow all countries, regardless of their level of development, to effectively mobilise revenues from the taxation of cross-border services without creating undue administrative burdens. I thank you.

Thank you very much, esteemed colleague from Estonia. Estonia, please.

Thank you, Chair. I'm only going to address the third bullet point because I don't think I have much to add to the conversation regarding the other points. But listening to this discussion, net versus cross-based taxation, as it seems to be going then, I wanted to point out that in the end, the final tax amount would depend both on the tax base and the tax rate, the combination of those. So a high tax rate on the net amount might not produce a bit, so to say, better final result than a very low rate on the gross amount. So perhaps we should discuss how much of the profits should we really tax in a particular country. And therefore, maybe then we can avoid this sort of controversy here, which isn't always really necessary. And as to the last bullet point, yes, I also think we should cover as many taxes as possible because also Estonia is a developed country, but we also get most of our tax revenue from the VAT. and it's really relevant. And VAT mechanisms, already they do tax income from payments from the digital services in any case. So it would really good if we could cover those as well. It would provide a slightly different point of view and would in general be very useful for the whole discussion. Thank you.

Thank you very much for those comments. Let me just make a comment from a sort of technical point from the co-lead on the taxes covered. We have income taxes, we have indirect taxes, we have direct taxes, we have excise taxes, and in fact, excise taxes can be applied on non-residents. Now, excise tax is actually defined as an indirect tax. So in the end of the day, this is not an easy subject when you want to sort of call things just by using the name of it. And I think we need to keep a very open mind on what we're going to talk about. We're going to talk about taxes. And probably we have to look at how those taxes are applied. Because I think we've heard digital services taxes, Are they income taxes? Are they excise taxes? Are they indirect taxes? I think it depends on how it's applied. And therefore, we need to keep that mind very much open. So thank you for raising that issue, both Jamaica and Estonia. And on the net and gross basis, I also think that was a very helpful comment from Estonia. in the end of the day, and I think also we heard from Saudi Arabia on thinking of a balanced approach. And remembering also, and I'm not too sure who's, I think it was Nigeria who said that, that if you want to have a net taxation, there's not going to be anything that stops you from having a net taxation if you file a return in that country. So, you know, we should probably get away from just locking in ourselves in the discussion on net and gross and look at the end result, which I think is what Estonia mentioned. So thank you for those comments. I think it's been enriched and it'd be interesting to hear if others have other comments. So with that, I have hand over the word, I think, to Italy.

Thank you, Lisa. Thank you, Chair. And congratulations for the issue note you wrote. It was not an easy task, definitely. I've heard with a lot of interest all the discussion and now particularly this last intervention from Estonian for you because I do not want to repeat what we had in our written comments. but for us also it would be fine to investigate more on the pros and cons on net versus gross basis taxation. We think that it could be guidance on how to apply different rules. We favor different rules for different types of services. We think that we could end up in a very open mind to define new nexus rule according to the business model we have. We are convinced that physical presence And also good TPP practice could still work for some kind of traditional services. I would also like to pick up something said by Saudi Arabia and others delegate that we should define more, we could dip more into the definition of services in order to distinguish between low margin services, not to overkill investment in that respect. So we are ready to work more on that. Thank you. I hope you heard me. And we are here to contribute as much as we can in the workstream work also. Thank you.

Thank you very much, Italy. Distinguished member from Lesotho, please go ahead.

Thank you, Chair. And like other delegates, let me just thank you for the work done so far. Just repeating myself on some of the issues that have been raised. For us, we think that a genuine business will always go for the market, not be so much concerned about taxes. And consequently, we just think that it is for the market to actually decide on the issue of tax incidence. In other words, there's nothing that we can do that will actually help us to try to address tax incidents. So let us leave that to the markets to actually address because in a competitive world, businesses are not so able to shift the burden of tax to taxpayers. So I think with that, we can safely say that we should not worry that much about the issue of tax incidence so that we are able to tax on gross. The African group and other many delegates have indicated that all that we need to be doing is to try to find the lowest possible rate of tax on which can use as proxy for net basis. So I think that will be our task to undertake. so that we do not go back and say that, because we tax on cross, it cannot work and tax incidence will always go to the taxpayer. That will be our input with regard to the issues raised. Thank you, Chair.

Thank you very much for that input. The distinguished colleague from Belgium, please.

Thank you, co-leads, and thank you for all the work that has been done on the issues paper and also by the secretariat, of course. We would like to align ourselves with the statements made or with the previous interventions from the distinguished delegates of Italy and Estonia, also to keep an open mind and investigate more on the pros and cons, but still taking into account that there are also good TP practices that might still suit for certain services, and we want to emphasise therefore also the importance of a thorough economic impact assessment still, because if you look at gross and net based taxation, we talked a lot last week also that there are guiding principles such as tax neutrality, and then we cannot deny that gross taxation will still have an impact on investment, Because it is likely to distort, um, businesses choices, so economic choices that they make, so there is a, a real chance on, on, um, providing, uh, still some, um… economic distortion, so we should be careful and therefore we want to emphasise that there should be an economic impact assessment that can guide us further also on what is the negative impact of certain choices, but still we want to keep an open mind and also as the delegate of Jamaica said, there are some practices already done on digital services taxation, excise taxes that was mentioned, so if we can see more how they were put in practice and what the results have been for countries that have try to apply them already, that would be interesting to see or to discuss here too, because I think that's important that we can learn from each other. That's why we're here too. Thank you.

Thank you very much, Belga. Distinguished member of India, please.

Thank you, Chair. On the issue of gross taxation versus net taxation, we would like to submit as follows. We agree that gross basis taxation for cross-border services offers certain benefits, particularly in terms of simplified administrative compliance and ease of enforcement. Since taxation is levied on the gross amount without the need to determine net profits, it reduces the complexities associated with expense allocation, transfer pricing adjustments and profit attribution. This can be especially advantageous for source jurisdictions, seeking a straightforward and predictable mechanism for tax collection. However, a careful consideration is required if gross basis taxation is adopted as a universal mechanism for taxing cross-border services. Countries with resident taxpayers providing such services abroad would be required to grant foreign tax credits for gross basis taxes paid overseas. This could result in net revenue outflows from the residence country and in some cases lead to situations of negative taxation where credits exceed domestic tax liability. Further gross basis taxation can unduly impact low margin businesses where tax on total receipt may substantially exceed the actual profits, which may lead to disproportionate tax burdens and undermine business viability. This may be problematic for service providers who may be operating on thin margins or in competitive sectors where cost efficiency is critical. We need to evaluate whether gross basis taxation adequately recognizes the contribution of the entire value chain or the intricate economic interlinkages involved in service delivery, particularly for multinational enterprises with globally integrated operations. giving due credit to jurisdictions where substantive economic activity and value creation actually occur. Therefore, a careful balancing is essential between gross basis taxation and net basis taxation. While gross basis rules can serve as a practical tool for specific sectors or transactions, especially where profit attribution is challenging, but they should be applied in a manner that minimizes distortions, ensures fairness, avoids disproportionate impact on low margin businesses and preserves alignment with the principle of value creation in a global economy. Thank you.

Thank you, India. Yes, certainly not going to be easy. Let me share a comment on the evaluation of problems and especially taxation and the benefits of tax treaties and if the cost actually that you have incurred by lowering your taxes has been paid off by higher investment. And in fact, my country when we had signed about Five years of tax treaties, we asked another organization, I won't name the name, but it's an international organization that does this. type of calculations. And they actually came back to us and said it's impossible to do. We can't help you, even if you have the figures, because you can't separate all the inputs of lowering your tax in the benefits of other issues that happens in your country. So I do appreciate what you're saying that we need to evaluate and I think we have to try to do that. It's just that it might not be that easy. And also when we do evaluate this, it's a deduction in one side and the other, the residence country has to actually give a credit for it. So when you do this evaluation, you have to look at both sides and supposedly if you have a double tax treaty, you have a credit for one side, so the net effect shouldn't be that complicated. But I'm not an economist, as you have probably by now understood, so perhaps some of you can help us a little bit more on that one. So I will now, I don't have any other. Sorry, you're getting enthusiastic. Very good. Austria, please go ahead, Veronica.

Thank you, Madam Co-Lead. I couldn't help but raise my flag eventually. Just to, I think we're having a very good discussion on some of the points. I just would like to lend my support, for example, on the fact, like Jamaica and others mentioned, we should really be careful with the impact analysis and use data in order to evaluate the different solutions that we're hopefully coming up with, keeping a broad mind, like you said, that we have different types of taxes that might lead to different possible solutions when addressing the challenges. One thing that now struck me when I was listening to the comments from other delegates is that there seems, when it comes to direct taxation at least, there seems to be two different elements of the problem or to different concerns that repeatedly come up, which I think we should be very careful to separate from each other when we start analyzing in more detail, which is on the one hand the fact of different nexus requirements or outdated nexus requirements, which is mainly resulting from services being able to be provided remotely and digitally and And I think this is one thing that we can have a look at when it comes to discussing how to allocate taxing rights under tax treaties. And I think the other issue is transfer pricing, and I think this is a thing that only comes up within MNE groups, of course, whereas the question of what nexus we use, this is a much broader issue. It's not only MNE groups that are affected by this. And so I think my input and maybe narrowing it down to the questions you had on the slide, this is something that maybe eventually is really a little bit missing in the issues node and that we should take into account going further, that we separate these two issues from each other because I think that it is from a technical point of view two different issues. Thank you.

Thank you, Ostra. Just one comment perhaps to clarify, so that I don't know if I was clear enough on the issue of taxes covered and the taxes that in my experience, when we have negotiated treaties, we have asked our counterparts if they apply taxes other taxes than income taxes that have the same effect as an income tax. In fact, in one of our treaties, and I suppose they are not secrets, so in our treaty with the United States, they told us we have an excise tax on insurance premiums. That's a cross-border service, and they apply an excise tax, which works exactly the same way as an income tax in my country. So, in fact, the solution in that treaty is to include the excise tax that the US applies on its insurance premiums in order to have reciprocal treatment in our treaty of payments to insurance premiums. So it is just an example that shows that we have to be very careful when we look at what we call the taxes. That is why I wanted to make sure that we understand that they can have a similar effect, although they are called indirect taxes, because the excise tax supposedly is an indirect tax, if you look at it in ChatGPT. I think we have Poland and then I think I'll leave over to the... No? You want to go? Okay. Please go ahead, Poland.

Thank you, Lieslot. Thank you very much for the work done and for the very interesting discussion today. And I would like to start with the... the issue of the gross versus net taxation and the treaty convention itself, I understand that if I follow also discussion properly, that in fact, how the profits are to be taxed in the source country is a decision of the country, independent sovereign decision. So it means that whether they tax these profits on the net basis or the gross basis, it's not an issue in fact. The issue is how we divide taxation rights in the international agreement, in the convention, in this in this case, and I understand that the idea is that we will do it on the gross basis, like in the case of passive incomes, and that the source country would have kind of threshold and that's kind of how much tax can source country collect from the cross-border services. And I see one problem in such a case because these are not passive incomes. They are always connected with some costs. So the profitability of the different types of services, different models, business models, can be totally different. So I wonder whether we can set up only one threshold, whether we would not complicate the system instead of simplifying it. I think that we should also think about this until we want to have these thresholds on the source taxation, then we cannot ignore that all the businesses can have a different profitability. And then the question is how many thresholds we would identify when we are referring to the gross taxation here. So I see that it can also be a kind of complication in this process. Thank you.

Thank you. So from that intervention, Paul and I understand that point four here, the possibility of different rules for different types of services, the way forward that we should work on now. That's what the take, I think, and I've heard it from several others. So thank you for that. I have Kenya.

Thank you, Chair. These are comments in national capacity. On the discussion of gross versus net taxation, We reiterate our support for gross basis taxation, especially because it is simple and easy to administer. But we recognize that there will need to be a productive conversation in terms of restricting the withholding tax rate that would be adopted so that in effect there is a recognition of the expenses of the taxpayer and also so that it can allow for shared taxation in both states. But we still have issues with adoption of net taxation because of all the examples that were given in the issues note, especially in terms of verification of these expenses. So we still are in favor of gross basis taxation, but a restriction of that taxing rates, which would in effect recognize the expenses. We also, in terms of the withholding taxes, we In our issues note, in our comments regarding the issues note, we also say that we don't see a blanket resolution being adopted in this protocol because it would be very difficult to find a one-size-fits-all in terms of the broad scope of services that we would want the protocol to cover. So we also see the need for consideration, for example, of simple apportionment, especially when We are dealing with the digital economy where we now no longer have only one source state. We could be dealing with several source states or we are now dealing with income being derived from a jurisdiction, but there's no payment going out of that jurisdiction from which tax can be withheld. So by virtue of that, we recognize that there could also be need to consider other forms of taxation, not just withholding tax, but maybe looking at a form of apportionment. On the issue of including analysis of taxation of goods, Chair, we would like to refer to the terms of reference that have made it very clear what is supposed to be considered under this protocol. Paragraph 15 states that the protocol should address taxation of income derived from the provision of cross-border services. in an increasingly digitalized and globalized economy. We barely have two years within which to fulfill this mandate. From the discussions we've had so far, we know that this is not going to be a small feat. So our position is that we need to restrict ourselves to our mandate, which is taxation of services. On the issue of economic analysis, I also just wanted to refer to the guidelines for intercessional work. which under paragraph 15, again, it is noted that it's the role of the Secretariat to provide support to the workstream discussions by collecting data and drafting analytical reports. We do believe that this analysis is important to the discussions. We believe the role has been given to the Secretariat, so we just want to reinforce the calls that we had in our general statements for the need to give the Secretariat the the support that it needs so that it can be able to fulfil its mandate as well and to give us this analysis that would be needed for our discussions. Thank you, Chair.

Thank you very much for that input. I don't think I have any Senegal, please. Go ahead, Senegal.

Thank you, Madam Chair. I would like to echo what was just said by Kenya. about following the gross calculation, which as it is more simple seems to give more advantages than the net system, but we should also bear in mind the need for a multilateral approach. If we stick to a multilateral approach with all the challenges we're facing, particularly when it comes to the verification of expenditure, it would be very easy to check if there's a net base, but if you have the gross base then it means that all of the incentives that are given need to be appropriately monitored and that could be harder. One of the delegations said earlier that if we speak about transfers and all of the adjustments then that could make things simpler but I think we should bear in mind the fact that in some regions, for instance in Africa, services are often carried out digitally and paid for digitally so this is something that needs to be borne in mind. We need to make sure that these services are appropriately traceable and can be taxed appropriately as well. Now, when it comes also to the taxes that are covered, we have spoken about indirect taxes, but I'm not sure if we take a multilateral approach how we're going to be able to address the issue of indirect taxes, because this is something that is sometimes difficult to ascertain and there's often not a lot of information about this. So I think this is something that we need to pay attention to. A tax on digital services is perhaps a way of achieving this, but we need to be careful that multinational companies are not able easily to find ways around these issues. So we need to make sure that we have an approach that is appropriate for all regions. There isn't a one-size-fits-all approach. Thank you.

Thank you very much. Nigeria, please.

Thanks. Do I say Madam Chair or Madam Co-Lead? I don't know which one better describes you. Okay, thank you for giving Nigeria the floor again. It appears the discussions around whether gross or net is becoming a bit unending, and expectedly so, but I believe that the the important thing or the most important is the effective tax rate, you know, because whether you tax on gross or you tax on the net, there's a particular rate that we're going to be using. And in my previous intervention, we had said that if you want to use the gross basis, you could use a lower rate that would be an approximation of the net basis for taxation. But We could also leverage on studies that have been conducted. I know that under the amount T, amount B, there were studies done by the inclusive framework around the effective tax rate. If we are able to look into things like that and conduct studies, then that will probably give a bit of comfort to all parties regarding prevention of over taxation, which is what I see that we are trying to guide against. The other issue that we also need to take into consideration is the end product of the work that we are doing. This, my understanding is, will likely be a treaty based rule and if it is not a multilateral instrument, if it is a bilateral one, then the parties will need to then sit and negotiate the rate which is exactly what we have when you negotiate Article 10 or 11 under a treaty arrangement. So it's not going to be that you have a fixed rate, but it could go on to be subject to negotiation by the parties to such rules. Thank you, Madam Chair.

Thank you for that input. That was helpful.

We have the Netherlands.

Please go ahead. Thank you, Colite. I quickly want to respond to what the distinguished delegate of Kenya just brought up, and it also goes to one of the questions that's presented here on screen, so the possibility of different rules for different types of services. Because if we are going to discuss the rates in the future of any withholding tax on services possibly, then we think that it's also good to think about certain services have different profit margins, so that would go for different kinds of rates that would make more sense on different types of services. Thank you.

Thank you very much for that input as well. Hungary, please.

Thank you, Madam Chair. I would like to quickly react regarding the net-based taxation versus gross-based taxation. And I would like to reiterate also others spoken so far that the economic analysis and impact assessment would be essential before we work out solutions and discuss solutions. So I would like to align also with Belgium and Italy what was said on this. Thank you.

Thank you very much. Then I think we have finished with Member States and we will look to stakeholders who have been waiting very patiently. I have first stakeholder 10, Bombay Chartered Accountants Society. Please go ahead.

Uh, thank you, Chair. Uh, in the presentation, there are four case studies and, uh, they are following certain pattern. Uh, each case study is asking us a question and, uh, you know, I thought the idea, idea could have been to, you know, uh, see how we can answer the questions which are in the case study. And, you know, if we attempt answering, then probably, you know, we will.

Realize the nuances of gross basis, net basis, et cetera. But that was about four hours back.

The discussion has gone a different direction.

So that's it.

Okay. Thank you very much. I have NGO2, which is the major group for youth and children. Please go ahead.

Thank you, Chair. My name is Alexa Dominique, and I'm speaking on behalf of the FFD Children and Youth Contingency of the Major Group for Children and Youth. The time-consuming nature of current tax policy results in increased illicit financial flows, driving us further from our shared vision of Agenda 2030. We cannot allow the time-consuming and resource-intensive nature of cross-border tax disputes impede upon the future of children and youth through underfunded schools, limited health services, and economic instability. Changes to the current rules of cross-border taxation are not merely necessary for aiding in the advancement of a global economy, but ensuring a future for children and youth. On behalf of MGCY, allow me to highlight three priorities of this protocol. First, as a global economy becomes increasingly digitalized, tax governance must keep pace. The current rules for cross-border taxation failed to take the future into account and will only further perpetuate current... perpetrate the abuse of tax systems within the digital world. Therefore, we believe that the idea that taxation should reflect real economic activities that take place in jurisdiction should be reflected into the protocol. This must include the value created by individual users in a digital environment. Secondly, the protocol should not discriminate between locally provided services and remote or digital services. Otherwise, local businesses, which are often owned by right holders such as young and indigenous entrepreneurs, will face unfair competition from multinational operations may not contribute the same level of taxes to the concerned jurisdiction. Noting these difficulties in distinguishing between different mediums of services, we urge for neutral, simple and transparent approaches to the protocol that do not allow tax avoidance through the artificial structuring of how services are delivered. Finally, we caution against implementation of gross taxes on low margin cross-border services as we believe that such policies may inhibit entrepreneurship and innovation, particularly in developing economies and towards young entrepreneurs. Excellencies, dear colleagues, children, youth demand a protocol that reflects innovation, inclusion and intergenerational justice, principles that will sustain both trust in governance and hope for the future. Thank you.

Thank you very much. I have the International Chamber of Commerce. Please go ahead.

Thank you, Madam Chair. Firstly, I would like to start by showing our appreciation for the work undertaken to produce the issue notes in such a short time, particularly given the complexity of the topic. I will not go into details of our written submission, which compiled contribution from our national committees and members throughout the world. Instead, I would like to focus on one of the goals that were presented in today's slides early on. As ICC, we support efforts to enhance domestic resource mobilization. However, as also highlighted in the FFD4 document, compromise to the Seville, this cannot be achieved solely through revenue contribution. Domestic resource mobilization is indeed also driven by enhancing cross-border trade and investment that create job opportunities and sustainable economic growth. We therefore strongly appreciate the goal of preventing barriers to trade and investment from guiding this protocol. However, we struggle to see how this goal can be achieved through gross basis taxation. As my esteemed colleague from ICC Pakistan also mentioned this morning, businesses across developed and developing world constantly tell us how distorted gross basis withholding taxes are. These do not account for the actual cost of providing services, raise the cost of doing business, and reduce returns on investment, which ultimately affects consumers and deters investment in a country. Refunds are also particularly challenging. Consider developing countries and emerging economies companies that want to export their services across their regions and beyond. Especially in a growing phase, there is being penalized for their own investment in supply chains, research and development, and innovation. We hear about this struggle from companies established and based in Africa, Southeast Asia and Latin America as well. We have also compiled our views on the matter on gross basis taxation in a series of written comments to the UN Tax Committee of experts in relation to Article 12AA, which we're happy to share with the rest of the intergovernmental committee. I would also like to reiterate another point raised by my esteemed colleague from ICC Pakistan. When new taxing rights are created, they still must be based on a proper economic nexus, a substantive engagement beyond the passive receipt of services. As solutions are further elaborated, we strongly recommend undertaking a comprehensive economic analysis of those. Tax policy does not operate in a vacuum, and the broader economic impact of any new tax policy must be analyzed before it is adopted. We, of course, remain at the complete disposal of the INC to provide experience and example from businesses around the world. Furthermore, we believe that today's discussions clearly show the value in the formation of a business advisory council that can be consulted for first-hand experience on all these matters. I thank you very much.

Thank you very much, ICC. Could I just ask all of you who make your intervention to slow down slightly? We do have some time. There's no hurry. And our poor translators are working over, spinning their heads. So please slow down. There's no hurry. I have Ataf. Please go ahead.

Thank you, Madam Chair, for giving Ataf the floor once more. We want to quickly respond to the issues raised and provide a bit of a response to each of them. On number one point, possible new taxing rule, I have believed that going by the issue note, members have rightfully acknowledged that the existing rules does not cover new and emerging business models appropriately. And by acknowledging that indirectly, the point has been made that there's need to develop new taxing rule. The question now becomes to, What range of services would the new taxes rule apply? New nexus rule apply? Will it just be applicable only to automated digital services or to other heads of services? And I think that would have to be determined by members in the design of the rules as they were. We also want to respond to net and gross basis taxation. We believe that gross-based taxation has worked very well for a lot of our members across different jurisdictions. But we also recognize the concern raised by some members of this committee that it could lead to over taxation. And the middle point of that has been outlined by Nigeria in saying that we would have to look at tax rate, which may be a fair approximation of net-based taxation. If we were to take that further, we can also have instances where net-based taxation could maybe serve as a backstop, outlining some basic rules and terms upon which that could operate, like having fair and accurate documentation as a precondition for the company to be taxed on a net basis. Then another item which you want to respond to is taxes covered. We have mentioned this in our written comment and we just want to reemphasize it again. It's very important to focus the work on income tax or functional equivalent of income taxes no matter how described. And by implication, we are also advocating for exclusion of indirect taxes or functional equivalent of indirect taxes as Focusing on that may not yield the targeted result in terms of trying to ensure that the tax burden is appropriately placed on the MNEs as against the consumers. On those three points of ours, Chair, we yield back and we thank you.

Thank you, Attaf. I have NGO one, which is Oxfam. Please go ahead.

Thank you, Chair. We appreciate the work that has been done by the workstream and particularly by you with regard to developing the issues note. We especially appreciate discussions on new nexus rules. We do believe that the current nexus rules are not aligning with the existing business models. However, we are severely concerned that the issues note does not adequately address transfer pricing concerns. Um, we believe that new nexus rules without addressing profit allocation rules makes the work of the work stream incomplete as it fails to take heed of the impact of profit shifting, which also severely impacts taxing rights. We therefore suggest that further to what has been covered within the issues notes in paragraph 12, much more needs to be done with regard to addressing several approaches to address transfer pricing concerns. We encourage member states to go beyond the limits of the fictional concept of separate entities within multinational enterprises. And our suggestion as civil society is that one of the approaches that should be seriously considered by this work stream and by the larger INC is unitary taxation and formulary apportionment. With regard to grace, gross-based withholding taxes amongst other gross-based taxation measures. We believe that this is a measure that works well for developing countries because of its ease of administrability as well as its simplicity. However, we do believe it's a short-term solution towards the challenges of taxation of cross-border services. We agree with the position that we should look to taxes that avoid passing the burden on the consumer. But we also state with regard to net taxation, in order for that to effectively exist, we will have to ensure that we have strong tax transparency measures, particularly public country-by-country reporting. And again, we believe that net taxation could come in under unitary taxation and formula apportionment. Therefore, we believe this is something that should be considered by the Member States on a balance of benefits as well as lack of benefits.

Thank you.

Thank you very much for that input. I do not have any more requests. Oh, I have one request now. Ghana, please go ahead.

Thank you, Madam Chair. I just thank you for the opportunity to add to our earlier statement. As we mentioned earlier, the question of whether there should be still a rule of fiscal presence, I believe that yes, it still exists. As we are looking at all the other fleets, they will still have break and water. And so that role will still be there. then we'll need new rules to cover the new ones. In terms of the net and gross basis, for those of us who are familiar with the Ghana treaties, we've always kept services separate from other business income because of the nature of the way businesses have operated. And so with our typical P's, we'd have the net basis in terms of determining how they pay their taxes. And then the gross basis is therefore all the other services, since the issues that have raised as to the complexity in dealing with them always crops up. We actually even came out of the service PEA bit earlier than others in our treaties. just to take care of services. But we agree that those rules that we had are still not enough and the need to look at all these rules again. And so the gross basis seems to be generally a simpler method for all of us. The net basis would have to look at it very critically because that is what generally will bring out disputes and Though I know workstream three would like a lot of work to do and a lot of importance placed on what they do, will prefer dispute prevention to dispute resolution. So when we are looking at net basis, we'll have to be very careful and have very tight rules in order to help everybody. On the issue of taxes covered, again, we are looking at simplicity. With the income tax, as we generally see, it in itself has its issues. Bringing other taxes, which normally wouldn't be, should I say, allocated among states into the discussion could generate some further complexities. SSI taxes are basically within the state, they are internal. And so we yet to really move SIs taxes outside the state jurisdiction. GST or that's general service tax or VAT again is on the consumer. And even if I'm asking some non-resident to charge that tax, It is on the consumer, who the person consuming it, who it's easier to identify and therefore shift that income to where it is. I'm here to see how many jurisdictions really share VAT proceeds or VAT taxing rights. So, I mean, as I mentioned earlier, nothing is impossible. it could happen in the future. That is when the new, we could have rules that are speedy and can cover them then. But in that case, it would be good to start with the simpler ones, which is the income tax, and move to the other ones if they need be later on. Thank you.

Thank you very much, Ghana. We have India, please go ahead.

Thank you, Chair, for giving me the opportunity again. I will make a short intervention only on the issue of whether taxation of income from provision of cross-border services is to be categorised or the taxes covered as direct, indirect or otherwise. In this regard, I concur with Kenya's position, as the terms of reference explicitly state that the protocol is to address the taxation of income derived from the provision of cross-border services. And from a conceptual standpoint, income tax relates to the income earned per se and determines the overall tax liability based on resident source or both. Whereas in contrast, service tax, VAT, GST, they focus on the transaction itself, which is levied on the supply of service per se. And given this clear wording of the mandate, the discussions I believe fall squarely within the ambit of direct taxation, especially income tax. Considering the same, it is appropriate that we limit our discussion into the realm of direct taxes because mixing the two could lead to definitional ambiguities, policy overlaps and potentially conflicting recommendations. It is therefore important to establish this clarity at the outset so that the negotiations and technical work remain focused and ensuring that subsequent steps are aligned with the protocol stated scope. And this would also help in avoiding any kind of a jurisdictional or interpretational disputes which may arise later in the process. Thank you.

Thank you very much. I have Saudi Arabia.

Uh, thank you, Chair. Um, maybe a comment on the issue of direct and indirect taxes, maybe echoing the comments already said by, by our, uh, colleagues in the, and the others, is that I think the focus should be more about direct taxes rather than indirect taxes. And I think this is the issue most jurisdictions are facing today. And when it comes to, for example, in Saudi Arabia, when it comes to VAT, it is implemented on transactional basis. And although there are some challenges in enforceability, but it's not a problem about taxing right, but it's maybe a problem about coordination and cooperations among jurisdiction to enforce collections rather than trying to solve-- rather than there is an issue in taxing right and the way they are taxing that need to be solved. So I just want to echo that and I think the discussion should be focused more about direct taxes. Thank you.

Thank you very much. Sambia.

Thank you so much, Madam Chair. And I just wanted to say thank you for the work done on the work stream and the presentation as well. So as Zambia, we support the statement that was delivered by Kenya on behalf of the African group. as well as the other African countries that have spoken before me. We just wanted to give our take on the national level, Zambia, with the questions that have been raised so far. And we do agree, and I think that's the general view from most people, is that we should, that we need to obviously agree on the nexus rules when it comes to what is going to be included for cross-border services. However, the other argument, I think, which is the third one, as to whether we should include -- thank you, thank you, I had to keep turning -- to the net and gross basis taxation. I do support that we should consider gross basis taxation. because clearly coming from a developing country on the net basis has brought a number of issues and complications. And most, and the common one is obviously the profit, it's used as a profit shifting scheme by most multinationals. And if we use a net basis, I think then we get back to the problems that we're currently having of exaggerated expenses, especially management and consultancy fees coming from Zambia, which is the largest expense that is usually claimed when it comes to cross-border payments. So therefore, that's why I think we would support the gross basis taxation. But however, noting to say that maybe we use a lower rate of, a lower rate be adopted. And obviously the effective tax rate, as mentioned earlier, could be something that we could consider and keep it within those margins when it comes to setting up the rate. And this, I know, would be difficult to apply for different type of services, as mentioned, because we are looking at a possibility of different rules with regards to the services. And then I just wanted maybe clarity on the issue with regards to the economic impact analysis that's been mentioned by member states. I know Jamaica was one of them. Is it something that needs to be delivered? I know because we're looking at a different timeframe. So is this to be delivered by the work stream and what timeframe would we be looking at because obviously looking at the complications and what will be involved in coming up with that impact analysis. And also, if we had to use the impact analysis, would it be for all member states? Would it suit all current member states' positions as well? That's a bit of my concern. I just thought I should mention that. Thank you.

That's my concern too. Thank you very much for that input, Sambia, and I think that is something that we have to look into and try to come back with some responses to that. Now, I do not have any more hands, so I will give the floor back to the Chair. Please, thank you.

Okay, distinguished delegate of Jamaica.

Yes, Chair, just a quick response to Zambia that the impact analysis, as Kenya stated, is in the terms of reference, and so the point I was raising is that we need to start looking at that soon because of the short time. So it is a part of the terms of reference and it should be carried out by the secretariat. I raised other examples of similar type taxes that has been introduced. The DST, the UN work on it, the OECD work on it and said we could draw from those examples. So I just wanted to respond to that.

Okay, I think just to make this clear and if anyone knows something else, you can correct me. The impact assessment, it's not mentioned that you are. because almost I know that you are by heart, so it's not mentioned there. It's mentioned in the work plan, in the roadmap and the work plan. It's mentioned there because the secretariat are supposed to do the impact assessment. So this is one of the things that the secretariat facilitate, which is it's-- right, Patricia? It's in the guidelines, exactly. So it is in the set of documents that we developed the year after February session in this committee. for our roadmap, the work plan and the guidelines, that the role of the Secretariat is to provide support, one, two, three, like blah, blah, blah, and one of it, one of this support is to provide the impact analysis, but no reference to impact analysis in the, in the TR, just as a matter of, just to clarify and set facts on this. But what I'm saying is not I'm saying that it will not happen. Like it doesn't differ what is in the TOR and in the guidelines. It's just saying what is the type of document actually it exists. But anyway, even if it doesn't exist in both documents, I think it's still important to do it. So we'll do it anyway. But just letting everyone to know where exactly this is mentioned in which document, I mean. So I think we were planning here just to go for a break and to come back. This is one of the ideas. But I think when we go for break and come back, we'll be very limited in time because we still here have some questions, some points that we would like to raise. So we will not get enough time to have this interactive discussion and give the floor and go through it. And we don't like to cut the discussion in the middle. because we are left with one hour maximum. So we propose that we can close for today because actually we heard different and diverse and versus point of views that deserve to be digested not only by us but I think by everyone here and we can come tomorrow morning with a fresh mind about it because this it's not an easy topic for me I consider this topic exactly especially to be one of the biggest and the core of this process. And I think we'll take a long time on it to talk and just to analyze this topic. So I think what we are going to do now, we will keep our questions or points for discussions for tomorrow. We will give opportunity to everyone here to go and digest and think about these questions and other even in the presentation and how we can address this. And just we come back tomorrow to reflect on these questions again and maybe more and further ideas and, and points that will be raised for, from the podium. So I would like to thank everyone here and wish all of you a good evening and see you tomorrow in the same room at 10 a.m. morning. Thank you all and good evening.