Mr. Pascal Saint-Amans:

It is not incorrect, but I am not sure where the Chairman wants to drive me or whether it is appropriate for me to comment further on the US system as I have not prepared on this topic. I will, however, make an overall comment. Earlier I stated governments had accepted the opening of some loopholes in their tax legislation which facilitated or favoured their champions or multinationals. An example in Europe is the watering down of controlled foreign corporation legislation as a way to protect one's tax base in a territorial system. The United States introduced the check-the-box system which some then tried to repeal when they realised its major impact. Companies indicated that they would be put at a competitive disadvantage if the US system was repealed because of European countries with weakly controlled foreign corporation legislation. This is the type of implicit behaviour which has taken place. All countries, including the United States, European countries, Japan and other G20 countries, now have the will to put an end to this type of practice. That is why the base erosion and profit shifting project has such support. Countries are also concerned with levelling the playing field and ensuring they move in the same direction at the same time.