Russell Deborah; Watts SimonHon Dr DEBORAH RUSSELL (Labour): I just want to carry on to another clause which is to do with penalties as well. So it is in clause 75 and it is the Penalty"—it was originally "Penalties"; it's now "Penalty"—"for failing to register or provide information for purposes of applied global anti-base erosion rules". So the previous penalty we talked about was the one which was to do with the failing to meet the country-by-country reporting rules and that was assessed at $100000 applied at the commissioner's discretion and so on. And this one sets a similar amount. It's "the amount specified by the Commissioner which must not exceed $100000." So I'm taking it from what the Minister has just said that that has been set by reference to the size of the entities and by reference to the similar amounts in other jurisdictions. So that all makes a fair amount of sense.But there is another aspect that's sitting in this and it goes into the other clause as well. It sits also in clause 74 new section 139AAB and that is the due date for payment of the penalty. And it's the same in both clauses so the question will apply to—sorry in both new sections. So the question will apply to both new sections. So "The due date for payment of a penalty imposed under this section is" either "30 days after the date on which the Commissioner issues the notice of assessment for the penalty:"—so that's a fairly straightforward 30 days—or it is "the date specified by the Commissioner in the notice of assessment as being the due date for payment of the penalty." So again this probably goes to the commissioner's practice. It says 30 days or it says a date that the commissioner can specify.Now we can see that that could be problematic. Having worked with many of the fine officials at Inland Revenue I doubt that they would issue the assessment one day and expect the penalty to be paid the next. But what I'm seeking from the Minister is some assurance that in general the commissioner is aiming for that 30 days. But in particular what would be the circumstances in which the commissioner might choose a different date? What might sort of push the commissioner to instead of going for the 30 days make the commissioner elect say 40 days or a particular date? What might push that payment date out? I'm really asking for some assurance that the way that the commissioner is going to apply her or his discretion in that matter is a way—well I'm not sure that we want to say that it's taxpayer friendly when we're issuing penalties but at least doesn't impose extra burdens on the taxpayer rather than just the burden of the penalty itself.Hon SIMON WATTS (Minister of Revenue): Just in answer to the member's question the penalties regime and the discretion in terms of the timeline afforded—not only in the 30-day aspect but also in the discretion around the commissioner—is also consistent with other penalties that apply to these entities. So it's not inconsistent. That is how that works. I think it's important to recognise that we are talking about 20 to 25 entities specifically under the global anti-base erosion rules. These entities generally are highly compliant with New Zealand tax legislation and that's because of the factors that we've talked about in terms of both in-house and external counsel and they also have obligations in terms of subsidiaries of multinationals. But in addition to that they're also captured under the significant entities team within IRD. So the case management across that is also another layer of ensuring adequate compliance."