Mr. Mike Lewis:

We also have not looked at the Italian proposals in detail. We note, however, that there are always concerns with turnover taxes on digital sales and sales taxes in that they might more easily be passed to consumers and users as a matter of practicality than profit taxes. As such, our overwhelming message is that we want to get profit taxes right.

In terms of where the OECD is at, we have discussed this in some detail already. While we have said we are supportive of some of the areas of the existing BEPS package which could help in this area and which Ireland has yet to implement fully, it is worth noting that the original BEPS package was not intended to address two areas which the EU proposals do address. The first involves situations in which there is absolutely no presence on the part of a company in the jurisdiction in which its customers reside, which probably would not be dealt with by the kinds of PE adjustments in Article 12 of the multilateral instrument. I think that is the case, but I look to other experts around the table in that regard. The second area which the EU proposals address is the question of whether profits should be attributed based in part on the value created by users or their data. In that sense, there are things the EU is trying to do which are not in the current BEPS package. Our message is that, once again, these are things which are being considered within the inclusive framework under action 1 of BEPS now but there is still disunity in the area. We urge all members of the inclusive framework, including Ireland, to be ambitious in that area, in particular in order to deal with those two problems.