Mr. Seamus Coffey:

Potentially, it will be, but if we look at the 140 countries that have signed up under the inclusive framework, it includes the Cayman Islands and Bermuda. They are not going to levy 15% on anyone. They do not have corporate income taxes. They cannot have a 15% rate. They will continue to have no corporate income tax. They have signed up to this. They would have been central to some of the most aggressive tax minimalisation strategies that we have seen. I accept it will have some impact, but a key will be the home country of those multinationals. That is the reason, from an Irish perspective, a lot of the focus will be on what is happening in the US and whether it has OECD-compliant minimum tax. At present, it does not look like it. Given the way the congressional elections have gone, it is hard to see anything happening in the next two years that will change anything over there. The global intangible low-taxed income, GILTI, is a form of a minimum tax but it is at a lower rate and a different base. Making it compliant with what the OECD has agreed is not straightforward. It must be brought through congress. The President cannot magic it up. It must come through Congress, so that will be a difficulty.

Does it reduce the aggressive tax practices we have seen? It has some impact, but I think other changes have been far more significant. I refer to changes in transfer pricing rules and the US itself getting rid of deferral. Those have had a much bigger impact than the minimum tax will have.