We'll put us in a bit of a back foot from a time point if you would like to invite the presenters to just come up front and we'll shoot off to the questions from the floor and from online. Suffice to say that whilst they're coming to the front that it's to be welcome that there is an atlas of offshore world that most of the developing countries will be looking forward to, especially for asset classes you can come through, especially for asset classes that are not financial necessarily, including real estate. So I think most developing countries would want to have sight of that information. Niels, you can join, Dario. And whilst you prepare your questions, I think it's also important Niels that at some point we do understand what the implication of the voluntary disclosure programs becomes on the 10 billion rents gap that we see because I think there could be some blind sighting if you are not able to see what voluntary disclosure programs were affected in the same period and how that plays into the return information because the assessed information is better than the return information in as far as any intervening disclosure programs that could have been ran in 2017, 2018. So I think it's important to bring that into the gap but I'm sure South African colleagues on the floor would ask questions. I'm open for questions from the floor. There's a roving mic and we will interchange for two questions we take on the floor. We will take one online and you'll indicate if you've got one. Hi. Thank you for the fascinating presentations. I have two questions. One is for Niels.  My initial expectation was that the black line might come down as tax advisors do their job and people get around the CRS. So isn't the fact that the black line stays up already amazing news for South African revenue collection and result in itself? The second question is to Angela, you talked about this process of how information exchange got better and better from kind of a rough start. Do you think that's a useful way going forward to kind of start with something and then improve upon it? There are other initiatives such as the EU tax haven black lists for example which are kind of wasting a lot of political momentum by just, you know, making one list less salient than the next and so forth. So you can also lose political momentum when you kind of have to go through all these stages before you have the system you wanted from the start. So do you think it's a valuable way for other initiatives to approach like, to proceed like that? Maybe let's take the second question and then we can allow the members to respond. Thank you. I agree with Jakob for great presentations. I really enjoyed all of them. I have a question for Annette. Maybe a bit of a provocative question. It's an awesome paper, but I want to dig a bit deeper on the policy conclusion that we need to extend the CRS to real estate. I see the point for the Norwegian case where you have a wealth tax. I think the case would be much harder to make to, for example, a German politician that can't result a wealth tax. I think they would tell me, well, you know, we can't tax the real estate in Dubai anyway, so why put that effort on them? If they rent it out and have income from them, the income ends up in a bank account and we see that in the CRS. So do you think there's really a worldwide case for making this effort to include real estate in the CRS? Thank you. Maybe let me allow Annette to take that question from Dominika first and then I'll turn to Nils. Thank you, Dominika. I think your starting point is that I agree that the reason why the German should have that, that two reasons, like transparency is good. Like, you don't know who owns assets in any case. We have many reasons beyond taxes, beyond the wealth tax, but there is also the income to get income tax. And you're basically assuming that CRS would capture that income tax, that it would go to a bank account in Dubai or something. Like, it's, things are a bit more complicated than that and CRS doesn't work if you have it. Like, there are ways to get around that with different holding companies and different structures. So I think the German Minister of Finance should be very interested in having this information. So the question, I guess, from Jakob was like, so I showed you a black line indicating kind of the aggregate assets owned by South Africans reported by foreign banks. And it was kind of like decreasing slightly, but more or less constant, also like the income. No, like this, like slightly decreasing, but more or less constant. And so I guess there are a number of different interpretations. So I guess you're right that this means that assets have not, you know, gone into crypto or real estate or like other things that are kind of outside the scope of the CRS to the extent where income is just plummeting. But I guess it also means that people have not moved, which would maybe be even more desirable, have not moved their assets back to South Africa to the extent where like the income is now like accruing to South Africans account will be easier to monitor, I guess. So I mean, I think it's not explicit goal of the CRS to induce repatriation. Like it's fine if people keep their assets abroad as long as they can now be taxed. But I guess it's still easier for compliance purposes if people would repatriate their assets into the domestic realm. But I guess like, so I guess the answer to your question is that it's a little bit bigger is what that means and how good news it is that the income has not gone down offshore. Thank you, Jacob, for the question. I think I will respond the first with analogy. Before you learn how to jump on one foot or run, you have to learn how to walk. And I think that's very true for daily life as well as for implementation of complex technical projects. The reality is we would not have had a UI without having put in place mechanisms for implementation of a UIR first. You cannot have CARF and capture cryptocurrency assets before we went through the stage of a UI to start with. So it's always pace to put foundations first and then improve it. Obviously, when you speak about big ideas it's good to imagine the end result and it's important to appreciate technical difficulties and complexities and bringing it closer to the exchange of information. Appreciate all sorts of assets and all sorts of behaviors and all sorts of avoidance or evasion strategies that you can use in order to avoid the existing framework. It's important to have that inside but also equally important is to make step-by-step progress. Otherwise, as we could see, you can leave some countries behind because not everyone can adjust to the same high speed. Otherwise, you can do something in the wrong way because as you implement the basics you also learn from that. So yes, answer to your question. I do believe in the gradual process. I do believe that we should go through certain stages before we can get to complete what would be regarded as an ideal scope of exchanges of information as such. Thank you. Thank you. We'll take another round of questions. By show of hands, there's two hands. Hi, thank you so much for very interesting presentations. My question goes to Dario and the question of tax amnesty in the Argentine. I was wondering seeing as the effect was biggest after 2016 if the Panama Papers leaks was controlled for and also the effect afterwards seeing as, I mean, there has been many leaks but that has maybe been the first big global one if I'm not mistaken. I was just wondering if it was accounted for. Thank you. I think the question is clear. There's another hand. Thank you so much for the wonderful presentations. I'm just wondering, is there a possibility that some of the funds in offshore accounts have already been taxed? And then I'm thinking about the CRS forms.  Does it mean you automatically are prompting registration or it could be that probably the other jurisdiction, the tax pay identification? Thank you. Thank you, Dario first. Yes, thank you for your question. Yes, certainly the Panama Papers were leaked in May 2016. The amnesty began in June 2016, right? So in the paper we tried to, we don't take a strong stand on the amnesty being the main driver or the miracle of, the reason why people disclose assets. We believe it's a big factor. We tried to argue that there is a combination of policies and I think the main takeaway is probably that is that today in 2023 there is like momentum to kind of implement these amnesties in a good way and try to take advantage of the information exchange agreements and that information is flowing across countries. We believe that Panama Papers probably, I know in Argentina people were freaking out at that point but there are many factors that I could explain and I think it's interesting to see that all these disclosures are quite stable after 2016, right? And that kind of suggests that it's not only the Panama Papers itself. Thank you, Nielson. Could those assets be already taxed? Interesting question. I guess the question was whether like this, so we are comparing kind of people, self-reported income to the bankrupt income in South Africa and I guess the question is whether like this income could have been taxed in a different jurisdiction. So that could have been with holding tax either where the securities are held or there could be people who really like have like multiple residences for example whether they have the year in London the other half a year in South Africa and I think you're right that some of these questions are important. I think, and I should double check this, I think what we've done is that we have conditioned in our sample on people being kind of fully taxable in South Africa, meaning that even if you pay with holding taxes abroad you still have to kind of typically, and I think this is true for South Africa too, you still have to report your full foreign income and then you will get like tax credit for the withholding tax you pay abroad. So that would be the typical case for someone who is fully resident in South Africa. That said, I think it's probably also true that there are other cases where you know people really like have many residences especially like very wealthy people and it can be complicated to like keep track of so where the income is really like an ultimately taxable and that can reflect something real that people really live in many different places but also the phenomenon that Dominika has documented that people also strategically can choose like to have a second account or a second address so that this year's report is sent to that other jurisdiction. I think that these questions about residents are super complicated and I don't think we pretend that we kind of fully understand it really in the data. Was that an answer? Okay, thank you. Thank you. I'll take one or two questions. We've got two minutes. Is the hand at the back? Hi, so my question is for Dario and I'm wondering, you know, you're sort of framing the thing like the amnesty was successful and comparing it to previous amnesties that were less successful but I'm wondering if you have sort of a finer sense of when the reports were coming in and in the sense that it seems like what was really different was that there was a credible threat that you were gonna get caught and in that sense, so if all of this wealth had come back anyways regardless of the amnesty then the amnesty just becomes like a way of, you know, relieving you really of the tax burden that you would have had to face anyway. So do you have any sense of distinguishing between those two effect or the effect of the amnesty itself versus the effect of the credible threat that you're gonna get caught? Maybe let me take an online question. I think you did try to answer that's a combination of factors but I'll give you a chance to come back online. Yes, so there are two questions. One relates to wealth tax and tax and offshore wealth in relation to real estates. Someone is asking how this affects public-private partnerships in terms of the advantages and disadvantages and also the second question has to do with the fact that ring fencing worked for revenue accrued from tax amnesty. However, some developing countries are still hesitant to ring fencing revenues. How do we convince them? Okay, we may need to settle back to the first question but Dario, maybe you can respond to the question. Thank you, Siakumo. You know, a statistic that speaks for itself is, you know, like almost 4% of GDP of this close wealth were real estate properties and you know, that's not captured by these CRS agreements, right? By the CRS, but so that's just that it's more than the threat of detection. Yeah, I guess that, for example, in the Amnesty before 2016, there was also a Swiss leaks and it was in the newspapers in Argentina and yet, you know, you look at the time series and nothing happened. So I think it's a combination of factors. That's what we try to argue in the paper. So we think that 21% of GDP is not only because of the threat of detection. So it's more than that. So it's an opportunity to come forward and yeah, in a safe way. I'm not sure that the online questions are clear Annette, do you want to give a sense of it? Yeah, I will give a more general answer to the, why do we need more information on real estate offshore? Because it's not building on what Dominica said. Like, why do you want to know that if you don't have a wealth tax at home? So this is going back to the opening session today. Like, it's not just about taxes. It's about secrecy and trust and legitimacy of the government. And if some people are able to hide their assets or ill-gotten gain from a home, if you can make hidden agreements, you can enable corruption. If you don't know what people own, you can't even hold them accountable for their hidden assets. So if they exploit their government or their power. But it also is important to say that when the journalists investigated a Dubai paper it's like who owned the properties all around. There were so many known criminals, or people who are convicted for tax fraud in Denmark, in Norway, people going bankrupt, hiding money from their creditors. And so it's basically unfair that people, some people can get away from their responsibilities by shifting assets abroad to a country that does not have any extradition. Like, for instance, there's no extradition agreement with Norway. So if you get to Dubai, you could, as a criminal, you could just hide there and live happy days with your ill-gotten gains. So for me, that's super unfair, basically. Sure, I think in view of time, suffice to say that we over time, I think it's important that we step back. Angela gave us a sense that maybe it's a paradox, maybe it's not so hidden after all if we leverage the power of information and information exchange. But more so that we create capacity to be able to consume that information and empower tax administrations to be able to act globally. Especially in the developing countries when that information becomes available. I think, again, I take a view on the differentiation between those countries that have got the wealth of tax and those that don't have. But I think I accept the final summation to say, for trust to continue to increase and the social contract to strengthen, it's important that citizens start to get a sense that these hidden assets are being exposed and the transparency is increasing and the tax administration and governments are taking action to deal with this. With that said, thank you very much for participating to our presenters and for yourselves for attending. The session is adjourned. Thank you very much.


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