Nash StuartHon STUART NASH (Minister of Revenue): In my experience in the House normally the first call on an amendment tends to be quite relevant to the amendment but that's OK. I mean that's fine. As Mr Bennett will know as the honourable member will know this is actually a tabled amendment by Mr Bayly to add another part to the bill. What Mr Bayly is suggesting this is about is that after five years we review the whole piece of legislation on base erosion and profit shifting (BEPS) to see what's happened with the OECD to see how the world has changed and to see if we're still relevant. Now there are two things I would say to this. The first thing I would say is that the Finance and Expenditure Committee only received one submission on a review of the bill and that submission was on a three-year review and it was specifically to do with the permanent establishment rules. That is all. It wasn't to do with the whole legislation whatsoever. So there was no widespread call for this at all. In fact you could say there's almost no interest in this whatsoever. But the most important thing I would say and the reason why we can't back this and why I can't back this as a Minister is because of something that the Hon David Bennett will be well aware of as a previous chair of the Finance and Expenditure Committee which is that tax legislation is always under review—it's always under review. In fact there are normally about two omnibus tax bills before the House every single year tidying up or changing or amending or deleting pieces of tax legislation. So what the IRD does is just business as usual. It just goes through legislation and it amends it appropriately depending on what circumstances are current and what aren't. So the US tax rate has nothing to do with this whatsoever. But what the IRD will do and what the IRD will continue to do—and keep it in mind that we have experts in this area and I've spoken about this three or four times in the chair. We have Carmel Peters for example who is a world expert in base erosion and profit shifting.Please don't think that as soon as this bill passes through the House then that's the end—we up sticks and we don't do another thing on BEPS ever again. Anyone in this House who has had anything to do with tax knows whether it's on select committee whether it's speaking on a bill—and you will be speaking on another omnibus bill soon—or whether it's even as a Minister of Revenue or having sat on the Finance and Expenditure Committee that tax law by its very nature has to keep up with the changing world. It has to keep up with the changing world. My concern is that if we actually passed a piece of legislation like this—this tabled amendment: new Part 3 of Mr Bayly's—then it might send the impression that You know what? We're not going to do anything for five years. We're going to sit back and we're going to let the rest of the world do whatever they do. The world's going to move on and we're going to do nothing until the review comes up." And the review of a piece of legislation like this would take about a year; it would come through the House—so all up let's say 12 to 24 months. Well that is totally unrealistic. What I would say is that IRD will not wait for five years to review this piece of legislation. They'll not stop looking at what's happening globally. They won't stop amending the legislation to make sure it is absolutely relevant and world class and maintains the integrity of the tax system because the integrity of the tax system is the utmost consideration of the Inland Revenue Department. So what Mr Bayly is proposing is something that is done anyway. What Mr Bayly is proposing may in fact send the very wrong message—that being that we're not going to do anything for five years. So what I can promise Mr Bayly and the previous speaker David Bennett and this committee is that Inland Revenue will not stop in ensuring that our base erosion and profit shifting legislation is in fact world leading and meets all the requirements of the OECD and continues to keep pace with the changing global market place. So that is why I simply can't support this tabled amendment. Thank you very much."