Ms Deirdre Donaghy:

The idea is if you have an element of that nature in your tax system, developing countries can request you include provisions in your tax treaties that effectively allow them to put additional withholding taxes on. At the moment, as the KDB currently stands and if it were to continue, because that rate gives an effective rate of 6.25%, it is potentially in scope of the subject to tax rule. Again, that is something that needs to be considered this year.