Public country by country reporting measure defeated by narrow margin in UK Parliament

Transparency advocates expressed optimism in the face of defeat after members of the U.K. Parliament defeated by just 22 votes a Finance Bill amendment calling for public country-by-country reporting of large multinationals’ profits and taxes.

The amendment, moved by Labour MP Caroline Flint and backed by MPs from all of the main parties and by tax advocacy groups, was defeated June 28 by a vote of 295 to 273. “A great result,” Flint tweeted.

“We are very much encouraged by today’s debate. Although the defeat is disappointing, the margin was very narrow,” Alex Cobham, director of research at the Tax Justice Network, told Tax Analysts.

Read more: My news story for Tax Notes, 29 June (paywall) published by Tax Analysts.

BEPS implementation is the hard part, tax experts tell MPs

Tax experts have told members of Parliament on the UK’s Treasury Committee that implementation of the actions recommended in the OECD’s base erosion and profit-shifting project faces some difficult challenges and will depend on maintaining an international consensus.

Asked about calls for greater transparency regarding multinationals’ tax, they argued that public country-by-country (CbC) reporting would not necessarily help people decide whether a company such as Google is paying the right amount of tax.

Read more: My news story for Tax Notes, 15 June (paywall) published by Tax Analysts.

Cross-party amendment to Finance Bill seeks public country by country reporting

A cross-party group of members of Parliament has called on the U.K. government to back an amendment to the 2016 Finance Bill to require multinationals to publish country-by-country reports of their profits and taxes.

Caroline Flint, a Labour MP and member of the House of Commons Public Accounts Committee, secured support for the amendment from 11 colleagues on the 15-person committee as well as two former PAC chairs, Conservative MP David Davis and Labour MP Margaret Hodge. Six of the amendment’s 14 backers are Conservative MPs.

While Flint said that the tide of public opinion is moving toward openness, some tax experts have cast doubt on the value of public disclosure, arguing that it is the task of tax authorities to ensure that multinationals pay the right amount of tax.

Read more: My news story for Tax Notes (paywall) published by Tax Analysts.

 

UK tax policy and the corporate tax base: a public consultation

I think we can probably expect the Treasury committee’s inquiry into UK tax policy and the corporate tax base to be more informative and fruitful than the public accounts committee’s inquiry into “corporate tax deals”.

The Treasury committee has invited submissions by 31 March. In the meantime here is the transcript of the Treasury committee’s first evidence session, held on 2 February.

See also: Taxing multinationals: BEPS outputs and the ‘digital economy’

Taxing multinationals: BEPS outputs and the ‘digital economy’

“We aim to solve this problem in the next two years,” OECD tax director Pascal Saint-Amans said in 2013, a month before presenting to G20 ministers an action plan to tackle  “base erosion and profit shifting” (BEPS).

Very little has been said in mainstream media about the impact of the BEPS project’s “final reports”, published last October. The rules governing taxation of multinationals will change, but they cannot be changed in a hurry, nor retrospectively. Campaigners have said for a long time that only fundamental reform will do.

Sol Picciotto noted last week that the OECD’s task force on the digital economy had “recognised that digitalisation means that [multinationals] have come ‘closer to the economist’s conception of a single firm operating in a co-ordinated fashion to maximise opportunities in a global economy’”. He added:

“[The task force] also accepted that this entails a ‘substantial rewrite of the rules for attribution of profits’. The report canvassed several possibilities … However, it could not agree even to recommend any of these, and left it to states to decide. Meantime, the task force will continue, aiming to produce a report in 2020. Plainly, we cannot wait that long.”

The OECD report Addressing the tax challenges of the digital economy said that work will continue following “completion of the other follow-up work on the BEPS project”, and the future work will be based on a mandate to be “developed during 2016”. It added that “a report reflecting the outcome of the continued work in relation to the digital economy should be produced by 2020”.

So the UK’s Treasury committee inquiry into tax policy and the “shrinking” corporate tax base is welcome. We can expect some more clarity than we have seen in some of the recent press reports, and some useful analysis of the possibilities for reform. The problem is even more urgent than it was in 2013, but the solution has to be the right one.

Treasury committee inquiry: Taxing multinationals and making tax digital

It may seem odd to put these two issues together but MPs on the Treasury committee have launched very wide-ranging inquiry into the UK’s tax system.

The committee has invited submissions on the making of tax policy, the problem of the shrinking corporate tax base and the administration of tax. This last item will address two key questions:

  • Has the merger of the Inland Revenue and Customs and Excise been a success, and have there been too many subsequent reorganisations within HMRC?
  • Are the plans for “making tax digital” adequately designed and acceptable?

MPs debated at length this week a petition, calling on the government to “scrap plans forcing self employed & small business to do 4 tax returns yearly”, which now has more than 110,000 signatures.

The government’s response to the petition was that

“Making Tax Digital will not mean ‘four tax returns a year’. Quarterly updates will largely be a matter of checking data generated from record keeping software or apps and clicking ‘send’.”

During the debate Chris Leslie, the former shadow chancellor, suggested that “people could be doing these things five times a year – there would be one big final return and these updates along the way”. He asked:

“Are we getting rid of the annual tax return or not?”

It was a good question because we have been told that we can expect “the end of the tax return”.

David Gauke, financial secretary, replied:

“The traditional annual tax return, we can get rid of. What I am saying is that, rather than starting largely from scratch and pulling all the information together, businesses that need to make adjustments at the end of the year will have already done much of that work. Now, as I say, the tax system remains an annual system, and one needs to be able to look at the year as a whole for things such as capital allowances. However, it is worth bearing it in mind that the capital expenditure of the vast majority – something like 98% – of businesses would fall within the annual investment allowance of £200,000, so that is not necessarily too much of an issue for them.”

There will be much uncertainty for small businesses during what will be a very long consultation period.

BEPS: OECD proposes “special measures” to shore up the arm’s length principle

Ofsted can make a school subject to “special measures” if it considers that the school is failing to give pupils an acceptable standard of education. I was reminded of this when an OECD paper published on 19 December proposed “special measures” to shore up the “arm’s length” principle underpinning the current, outdated international tax system. More on that below.

The OECD now has nine open consultations on proposed reforms to tackle base erosion and profit shifting (BEPS), following publication of six discussion papers in the week before Christmas. Continue reading BEPS: OECD proposes “special measures” to shore up the arm’s length principle

Luxleaks tax disclosures serve the public interest – prosecuting the source does not

More than 70 politicians and tax transparency campaigners have signed a letter to the Guardian deploring Luxembourg’s decision to bring criminal charges against a former PwC employee believed to have passed to the media confidential rulings awarded by Luxembourg tax authorities.

As The Guardian noted last night, 20 news organisations around the world have published detailed investigations into the tax affairs of several multinationals based on leaked tax rulings that PwC obtained in Luxembourg for some of its clients. Continue reading Luxleaks tax disclosures serve the public interest – prosecuting the source does not

BEPS: Priorities and concerns (Tax Journal)

The G20/OECD project on measures to tackle base erosion and profit-shifting (BEPS) appears to be on track despite a very ambitious timetable. But the project is still in its early stages, and there are signs that expectations may be running a little too high.

New Zealand revenue minister Todd McClay declared on 3 July that the OECD Committee on Fiscal Affairs (CFA) had “approved the final recommendations for the first set of actions”. G20 finance ministers are to consider a report of the CFA, following its meeting last month to vote on a series of “deliverables” representing the outputs of several discussion drafts, public consultations and working groups. But the OECD is not expected to release any details before finance ministers meet in the Australian city of Cairns in September 2014.

Read more at Tax Journal.

Tax transparency, public understanding and a shared purpose

The role of greater transparency in improving public understanding of tax issues and enhancing confidence in the system was the subject of an informative and good-natured debate at the House of Commons on 8 July, hosted by Mazars and the Association of Revenue and Customs and chaired by Margaret Hodge MP, chair of the Commons Public Accounts Committee.

My report focuses in turn on some of the key issues relating to tax authorities, tax advisers and taxpayers – three groups forming what Mazars has called the “transparency triangle”.

Read more on the Mazars Tax Transparency blog.

See also recent Published work.

The state of the tax debate (2): The importance of constructive dialogue

This is the second of two extracts from my talk on “BEPS day”, part of the Summer Tax Programme at the Centre for Commercial Law Studies, Queen Mary University of London on Monday, 16 June.

The wider tax debate continues, and like a lot of political debate, the tax debate is highly polarised.

Terminology is a problem. How can we have a good debate when we can’t agree on what the words mean?

What do people mean by “avoidance”? [Avoidance is legal, evasion is not. Some avoidance may become evasion.]

Many people say BEPS is avoidance.

Some experts say no, it isn’t avoidance [although it may be “aggressive tax planning”] because multinationals are merely taking advantageous of incentives, or gaps in the system, and they’re clearly acting within the law.

If you follow the finance journalist Paul Lewis on Twitter you may have seen him using “evoidance” with an “e” (not “avoidance” with an “a”) to describe some companies’ tax arrangements.

It’s not helpful, surely, for well-known and respected journalists to make up words which are bound to confuse the debate further.

The tax barrister Jolyon Maugham and others challenged Paul Lewis on this last week, but they were pulled up by the campaigner Alex Cobham for focusing on the language rather than the story – while the public get angry, tax professionals focus on the meaning of words.

“Give peace a chance”

Over the weekend Jolyon Maugham on his blog, and Alex Cobham in his response [and see more recent comments], have effectively appealed for those involved in the online tax debate to “give peace a chance”. And that’s well worth a read.

A small number of tax professionals – it is only a small number – do seem to spend a lot of time venting frustration on blogs and Twitter at a lack of tax knowledge and understanding shown by some politicians, campaigners and journalists.

But are they being heard? Generally, tax professionals have about a few hundred followers on Twitter. Some have more than a thousand.

But the PCS union has 16,000 followers, and Richard Murphy 21,000. Paul Lewis has 74,000. UK Uncut has 71,000 on Twitter and 68,000 on Facebook.

Sharing knowledge, improving public understanding

There is a massive, legitimate public interest in combating tax evasion and avoidance.

For too long serious tax knowledge has been shared and closely guarded by the relatively small number of people who depend on that knowledge for their livelihood.

Tax professionals are forever complaining that public, media and politicians don’t understand tax. But it’s arrogant to dismiss their concerns on the basis that they don’t understand.

It would be good if more of the moderate voices spoke out, contributed positively to the debate and tried to help to improve public understanding.

This is what a small but growing number of tax professionals have been trying to do just that for some time, including for example Heather Self at Pinsent Masons, Paul Morton at Reed Elsevier and Rebecca Benneyworth at ICAEW.

Last week for example Heather Self, responding on Twitter to a radio news report about Uber’s tax affairs, said this in a tweet addressed to Radio 4:

“Under current international rules, probably no UK permanent establishment. Rules do need updating for digital business…”

The character limit is a problem of course but it’s amazing, sometimes, what you can do in 140 characters. We need to see more of this measured, constructive engagement.

Transparency and reputational risk

I mentioned on the blog last week that Mazars is also playing a part. A consultation on the firm’s draft Board Charter closes at the end of this month.

The Board Charter includes a draft tax policy for companies to consider. The firm says it may be appropriate, as a guiding principle, that:

“… the amount [of tax] paid by a business in each jurisdiction in which it operates should be fair having regard to the amount of activity undertaken and/or value created there.”

There it is, the “fair” word. It may be controversial, but let’s have a proper debate about it.

Some tax professionals have told me privately that they don’t like to see giant internet companies accumulating billions of dollars tax-free in tax havens.

I believe that this disapproval, like their disapproval of evasion (which is unequivocal), reflects a sense of what is fair.

And Mazars hosted the recent debate on the Fair Tax Mark, which I wrote up for Taxation magazine.

Of course there are some real concerns about the FTM but at that meeting there was a lot of common ground.

Some very recent initiatives

Earlier this month Heather Self shared a platform with Richard D North of the Institute of Economic Affairs and John Christensen, director of the Tax Justice Network, at a debate co-hosted by JustShare and Christian Aid.

The topic was “Paying Up: Is tax a question of ethics?” You can watch the debate on YouTube.

It’s interesting to compare Mazars’ Board Charter with the CBI’s statement of tax principles, published last year. The CBI suggested that:

“UK businesses should only engage in reasonable tax planning that is aligned with commercial and economic activity and does not lead to an abusive result.”

PwC launched a debate on the future of tax only last week, with a view to producing its own “white paper”.

Kevin Nicholson, PwC’s UK head of tax, said his firm wanted to hear from “everybody”.

And last Friday the ICAEW held a “Tax Assembly” to promote debate about the future of tax – hashtag #taxassembly.

Rebecca Benneyworth, chairman of the Tax Faculty, was so pleased with the outcome that she addressed a tweet to George Osborne:

“@George_Osborne Superb tax event today between tax professionals civil society and others #taxassembly @ICAEW all committed to tax reform”

[For more on the Tax Assembly, see the Finance Innovation Lab’s report.]

Fair Tax Mark

A few things have struck me about the FTM, some of which emerged during the debate at Mazars.

First, several leading tax professionals have given it a cautious welcome, and I think this reflects a recognition that greater transparency is needed. There is some disquiet on the question of fairness, and I think this is the real challenge.

The aim of the Fair Tax Mark is:

“to help a company show the world that it is making a genuine effort to be open and transparent about its tax affairs and pays the right amount of corporation tax.”

But what is the right amount?

The FTM uses a set of criteria to determine whether a business has adopted a fair tax policy. And the fair tax policy suggests that the company is:

“seeking to pay the right amount of tax but no more in the right place at the right time, where right means that the economic substance of the transactions undertaken coincides with the place and form in which they are reported for taxation purposes”

The word “fair” is problematic for two reasons:

First, tax law is complex, with a range of allowances, reliefs and exemptions provided as matter of government policy.

As the CBI statement of principles said, companies are entitled to respond to incentives and exemptions.

So it’s difficult to judge whether a company deserves the accolade “fair tax business” without having a detailed knowledge of the company’s tax affairs and a thorough understanding of the tax system.

The second reason is that tax is, by definition, political.

It’s always a big debating issue at election time precisely because there is, inevitably, a range of opinions as to the role of government and how the cost of providing public services, infrastructure, security etc. should be shared. This is democracy.

Tax law is necessarily complex in parts (as well as unnecessarily complex in other parts) and there are lots of quirks and anomalies, making it difficult to discern the underlying policy.

So how likely is it that there will ever be a consensus on what “fair tax” is?

We should see the FTM’s criteria for multinationals soon, and everyone should have the chance to comment on them before they’re implemented.

But it’s worth remembering that the FTM team is a group of individuals who have decided to try to bring something like Fairtrade into the tax arena.

It is just possible that someone else might decide to grown their own FTM, or perhaps a Tax Transparency Mark.

Online debate

I’ve listed here some of the key players in the online tax debate [in no particular order, except that generally “tax professionals” are in column 2] and I recommend that you tune in to what at least some of them are saying.

Richard Murphy Professional bodies / firms
Alex Cobham Heather Self
Martin Hearson Jolyon Maugham
Margaret Hodge Ben Saunders
Tax Justice Network Mike Truman
Christian Aid Judith Freedman
ActionAid Iain Campbell
Oxfam Jeremy Sherwood
Citizens for Tax Justice “Christie Malry”

I’ll share one thing that’s been troubling me.

We’ve seen several reports from Richard Murphy – and from NGOs such as ActionAid and Christian Aid – that have been challenged by tax experts and others.

For example, Richard Murphy’s recent report on the cost of tax evasion and shadow companies was criticised by HMRC as well as tax professionals. He estimated that the total UK tax lost because of unrecorded sales alone in 2011/12 “might have been £40bn”.

That’s more than HMRC’s estimate for the entire tax gap, £35bn.

HMRC said his methodology was seriously flawed.

What I wanted to see (even if I had to do it myself) was a detailed assessment of that estimate and of Richard’s warning about shadow companies.

But the report runs to 80 pages, the executive summary is 20 pages. I wouldn’t say it was clear and concise.

The problem is that if Richard is 80% right, it’s a scandal. Tax evasion is being greatly underestimated. But if he is 80% wrong, that’s also a scandal because – given the amount of press coverage and the limited response – the message may well undermine confidence in HMRC and the tax system.

It needs someone with the time, patience and expertise to review such reports honestly, on their merits, picking out strengths and weaknesses.

Perhaps a post-publication peer review?

But who would do that, and who would pay? If that’s a problem, remember that Richard is backed by the Joseph Rowntree Charitable Trust and others including the TUC and the PCS. His reports are routinely reported in the press, and he has a huge following.

So perhaps some of the energy that is expended by tax professionals in venting anger on Twitter could be harnessed into serious, detailed appraisal of this kind of research.

Richard has many critics among tax professionals, but my impression is that very often the criticism is a reaction to his debating style rather than the substance of what Richard has said. He does talk a lot of sense, but the purpose of much of his output is to hit back at his critics. He does tend to tar whole groups or organisations of people with the same brush.

For now, let me endorse what Jolyon Maugham told Richard on Twitter this morning [16 June]:

“You have a manner that can engage people’s destructive impulses.”

Government and parliament

Some of the tax professionals’ frustration with MPs is entirely understandable. If you haven’t listened in to the Public Bill Committee debates on the Finance Bill, I suggest that you don’t bother. Read the transcripts instead.

How much of the committee’s time has been wasted, I wonder, by MPs trying to score party political points instead of doing what they were there to do – to examine the detail of some far-reaching tax measures.

It’s often said that MPs made the law, so they should change it rather than complain about multinationals acting within the law.

But there are two reasons why that’s not the whole story.

First, much of the existing tax law was already there when the current MPs were elected.

Secondly, as I’ve already mentioned, the only lasting solution to BEPS is international agreement, followed by the required changes to domestic tax laws and international tax treaties.

Uncharted waters

To sum up, we are in uncharted waters but there are positive signs and reasons to hope that the tax debate will become less heated, more constructive, and that more tax professionals will get involved.

And if you’re running a business and a level playing field is what you’re looking for, then the BEPS project seems to be your best hope.

If it works, it will reduce the reputational risk that all multinationals now have to live with – no matter what their tax policy.

The state of the tax debate (1): The BEPS project

This is the first of two extracts from my talk on “BEPS day”, part of the Summer Tax Programme at the Centre for Commercial Law Studies, Queen Mary University of London on 16 June.

I’m going to talk about the state of the debate around BEPS and tax avoidance, and the role played by the OECD, government and politicians, business groups, tax professionals, campaigners and the media.

There’s a lot to be positive about, I think.

The BEPS project is relatively new, still just a baby, albeit one that’s developing very quickly.

But the controversy about multinationals’ tax goes back many years.

KPMG said this in a paper called Tax in the Boardroom:

“Tax cannot remain in the ‘splendid isolation’ to which its technical nature and its perceived independence from the business mainstream have historically placed it. An attitude of benign assumption that tax is under control cannot provide the transparency demanded in these times of heightened sensitivity to corporate governance and responsibility issues.”

That was nine years ago.

HMRC said the KPMG paper noted that:

“Boards are coming under growing pressure to oversee their tax affairs in ways that reconcile their obligations to shareholders with the expectations of non-owner stakeholders, such as governments, pressure groups and the public.”

How much has changed since 2005?

In December 2010 a Financial Times editorial said country by country reporting would expose “the scandalous tax treatment of multinationals in the rich world”.

The FT said this:

“Current practice turns corporate tax largely into a voluntary gesture by the well-run multinational, whose methods of choice for locating income in lower-taxed jurisdictions are intragroup financial links and transfer pricing of intangibles such as intellectual property. As finance and intangibles grow in importance, so will the slipperiness of the corporate tax base.”

Last week the paper repeated the message, almost verbatim, in an editorial – the word “scandal” wasn’t in there, but the message was the similar.

Ambitious though it is, BEPS appears to be on track. On the face of it, big business is backing the project in principle. Reform at international level is seen as the only lasting solution.

But as the discussion moves on to deal with the technical detail, we’re now in a difficult period for many multinationals from a PR point of view.

Only last Thursday Brian Palmer, tax policy adviser at the Association of Accounting Technicians, was moved to write to the FT to point out that “steps in the right direction” were already being taken through the BEPS project.

Brian Palmer said the AAT hoped the outcome would be:

“a thorough overhaul of the existing outdated international legislation”

In the meantime, he said:

“… we shouldn’t lose sight of the fact that companies and taxpayers in general do have the right to organise their affairs in such a way as to minimise their taxation according to legislation.”

But on Saturday [14 June] UK Uncut renewed its tax protest against Vodafone, with so-called actions in nine British cities.

This despite the company having explained its tax position at great length and challenged what it called the “urban myth” of a £6bn unpaid tax bill.

How many of those taking part in the protests – the numbers were small, it seems – have tried to understand the tax issues? Perhaps all that UK Uncut needed to do was to point to Vodafone’s presence in Luxembourg.

So far as I could see, UK Uncut’s plans were completely ignored by the nationals in the run up to Saturday and by [Sunday] night only the Guardian online had run a story. Bu the Guardian website is hugely popular, with five million unique visitors every day, and this morning PSC, the union representing many of HMRC’s staff, retweeted a link to the story.

Why the lack of coverage elsewhere? Perhaps because the debate has moved on.

I’ve heard many times, in conversation with family and friends, people outside tax, something on the lines of

“These companies are doing nothing illegal, and if governments don’t like it they can change the law”.

Changing the law will take time. This was last week’s FT:

“The political and legal difficulties of agreeing mechanisms to avoid ‘double non taxation’ are enormous. It will take time to overcome them. For now, investigation, shaming and transparency may be the best tools to hand.”

The EC’s investigation into transfer pricing rulings concerns possible breaches of state aid rules, and the EC itself has pointed out that no one knows what the outcome will be. Ireland, at least, seems confident that there has been no breach. But the overall impression that many people will take from the EC announcement is that it’s further evidence of tax avoidance by big business.

For example, how on earth is the OECD going to bring about a single multilateral convention to replace 3,000 bilateral treaties?

“Kill 3,000 birds with one stone,” as Pascal Saint-Amans has put it.

“We will have consensus,” he said last month, but consensus “doesn’t mean unanimity”.

It means “everyone is sufficiently happy not to object”.

Understandably, the OECD hasn’t tried to estimate the size of the BEPS problem.

There’s been a focus on UK corporation tax and US multinationals recently, and there’s an “expectation gap” which you could define as:

the difference between tax paid and the tax that would be due under a system fit for the so-called digital economy

On the other hand, we don’t seem to hear about UK-owned businesses likely to pay less UK tax and more overseas tax if and when the balance of taxing rights changes.

BEPS is a critical issue for developing countries where, as the OECD said in its action plan:

“the lack of tax revenue leads to critical under-funding of public investment that could help promote economic growth”

Joseph Stead and his colleagues at Christian Aid and elsewhere are right to insist that developing countries are given a fair hearing.

And capacity building is of course a key issue for developing countries. Last month the OECD hosted a discussion on tax and development, in a live webcast.

Someone asked whether business could commit 0.7% of its tax expertise to developing countries’ governments to boost their tax take.

Alan MacLean replied on behalf of BIAC, the business and industry advisory committee to the OECD.

He said he thought most businesses would be happy to do whatever it took to ensure that tax capacity in developing countries was accelerated and grown to the level required for their tax systems to operate effectively.

He wasn’t sure that 0.7% was the right figure – it should be what’s relevant and appropriate in the circumstances and context of the particular country, he said.

Chris Lenon, the former chairman of BIAC’s tax committee, said in April that tax administrations clearly want interaction with business.

He wrote about the importance of educating tax administrations about multinational business models, but his understanding was that some businesses weren’t engaging because they thought to do so would be “too expensive”.

Surely multinationals themselves, as well as OECD, HMRC and Tax Inspectors without Borders, should be playing an active role in helping to improve understanding among tax officials in developing countries.

When I said that on my blog a few weeks ago, a few tax professionals expressed support for some kind of formal initiative. One asked me: “Where do I sign?”

But one contact told me he thought the problem might be that many companies’ tax departments were under-resourced – they have barely enough expertise to manage their own tax affairs.

There have been a number of public consultations on BEPS, and updates have been broadcast live on the web.

Of course, if you took part you might not be so happy about that.

I had to smile when a delegate at one of the public consultations objected to Richard Murphy live-tweeting the event as the OECS was broadcasting it live to the whole world.

The OECD’s last two BEPS updates were broadcast on the May bank holidays. But you can watch them back on the OECD website.

So the process is transparent. Or is it?

In May the Australian Treasury hosted a tax symposium in Tokyo, on BEPS and related issues. The event was closed to the media – apart from the opening and closing remarks.

A Tax Analysts report said a “troubling aspect” was the event’s sponsorship by “several firms and organisations that have a very big stake in the outcome of the BEPS project”.

Tax Analysts quoted Sol Picciotto, co-ordinator of the BEPS Monitoring Group, saying this:

“civil society should have at least equal representation with business at such events, and they should also be open to news organizations to ensure public awareness. This was far from the case at the Tokyo event”.

So that’s a real concern.

[More follows]