Mr. Pascal Saint-Amans:

In the international framework as it is, there are opportunities for companies to play on hybridity, transfer pricing holes, the definition of the permanent establishment as is, the lack of definition of beneficial ownership or the limitation of benefits in tax treaties, and the differences between domestic tax legislation regimes which facilitate the location of profits in jurisdictions where nothing is happening, such as some of the Caribbean jurisdictions mentioned. These differences are the result of domestic legislation in Ireland, the Netherlands, Switzerland, France, Germany and many other countries, including the US. Because Ireland has been competitive in its corporate income tax, it has obviously been used by a number of US multinationals, as has the Netherlands.