Edmonds BarbaraHon BARBARA EDMONDS (Labour—Mana): Thank you Mr Chair. And I too want to continue actually the line of questioning that the Hon Dr Deborah Russell has asked in relation to the global anti-base erosion (GloBE) rules. And to take the committee back to what exactly are the GloBE rules we look to the OECD and in particular pillar 2 which applies a global minimum tax. And actually one of the questions is what happened to pillar 1? So we're doing pillar 2 but when can we expect pillar 1 to have some form of agreement at the OECD? I wonder if the Minister can elucidate on that.The problem that this particular piece of legislation is trying to solve is that a number of large multinational corporate groups are able to pay very little tax on a worldwide basis. And they achieve this by basically carefully structuring and the use of tax havens. In particular tax havens become very effective for what has become mobile income in the forms of interest dividends and royalties. So this is a global issue and a global solution has been proposed by the OECD to prevent that base erosion and profit shifting. And it's had a long history through many different Ministers of Revenue. I think the first time BEPS—or base erosion and profit shifting—the actual proposals were first in were 2015 with Michael Woodhouse. And I might stand corrected but I do remember the Hon Judith Collins actually signing off some of the multilateral instruments to allow for tax information exchange between countries that are signed up to this multilateral instrument.So this bill proposes the solution and it's an OECD initiative whereby large multinational enterprises or MNEs can actually be subject to a requirement to file information returns and potentially be subject to the payment of a top-up tax. The question the committee considered was who will be affected by these rules? It is multinational enterprises with consolidated revenues of above €750 million in any two of the proceeding four years. So another question for the Minister is how many taxpayers do we think in New Zealand will be subject to these particular amendments in this clause 44?So the OECD proposal consisted of two main parts and the committee had a really good look at this. And those two main parts are the income inclusion rule and an under-taxed profits regime which is in some ways that sort of top-up. Together they are what we call the applied GloBE rules. Again multinational enterprises can have imposed upon them reporting obligations or an obligation to pay a top-up. And the potential impact of the regime from New Zealand's perspective depends on whether the enterprise is actually headquartered here in New Zealand or if it's headquartered out of New Zealand they could be liable for that top-up tax if they have an intermediate parent located in New Zealand or if they have liability under the under-taxed profit rules.So my third question to the Minister other than how many large multinational enterprises do we think may be applicable to the applied GloBE rules in New Zealand is how are other countries in the OECD actually applying these rules within their jurisdictions? Because as the Hon Dr Deborah Russell has said in clause 44 we make reference to basically the commentary that agreed administrative guidelines would prevail over the model rules if inconsistent I think. But basically saying that we will look to the OECD rules and the guidance that they provide and impart that obligation on to those multinational enterprises based in New Zealand that have over €750 million.So just those quick questions to the Minister. How are the other OECD jurisdictions? Are they following similar to New Zealand which is when it's a reference to the OECD rules? Or are they putting in primary legislation which is their own rules? Secondly how many multinational enterprises in New Zealand will be subject do they think to these rules? And probably just throwing it in there what about pillar 1? Thank you Minister.