| Return to Contents Harmful Tax Competition And The Challenges For Jersey Colin Powell Over the past year particular attention has been focused within the international community on the subject of "harmful tax competition". The main elements in this respect are - (1) the pean Union Code of Conduct on business taxation adopted on 1st December 1997; [1] (2) the proposal a European Union Directive to ensure a minimum effective taxation of savings income in the form of interest payments within the Community, issued on 20th May 1998; [2] (3) the report by the Organisation for Economic eration and Development ("OECD") Committee on Fiscal Affairs on "harmful tax competition; an emerging global issue", published in April 1998; [3] (4) a communiqué issued by countries in May 1998. (The G7 countries are Canada, France, Germany, Italy, Japan, United Kingdom, USA.) [4] European Union Taxation Policy On 1st December 1997 the Council of the European Union and the representatives of the Governments of the Member States meeting within the Council discussed the need for co-ordinated action at European level to tackle harmful tax competition in order to help achieve certain objectives such as reducing the continuing distortions in the Single Market, preventing excessive losses of tax revenue and getting tax structures to develop in a more employment-friendly way. Three areas were particularly highlighted - The Council agreed to a Resolution on a Codnduct for business taxation [5], approved the text on taxation of savings, and considered that the European Commission should submit a proposal for a Directive on interest and royalty payments between companies. Code of Conduct for Business Taxation The Code of Conduct embodies a political commitment and does not affect the Member States’ rights and obligations or the respective spheres of competence of the Member States and the Community resulting from the European Treaty in respect of taxation policy. The Code of Conduct is not therefore a legal document and does not have the force of law. The Code of Conduct concerns those measures which affect, or may affect, in a significant way the location of business activity in the Community. Tax measures which provide for a significantly lower effective level of taxation, including zero taxation, than those levels which generally apply in the Member State in question are to be regarded as potentially harmful and therefore covered by the Code. When assessing whether tax measures are harmful, account may be taken of: (1) whether advantages are accorded only to non residents or in respect of transactions carried out with non residents; (2) whether advantages are ring-fenced from the domestic market, so that they do not affect the national tax base; (3) whether advantages are granted even without any real economic activity and substantial economic presence within the Member State offering such tax advantages; (4) whether the rules of profit determination in respect of activities within a multi-national group of companies departs from internationally accepted principles, notably the rules agreed upon within the OECD; and (5) whether the tax measures lack transparency, including where legal provisions are relaxed at administrative level in a non-transparent way. Member States have committed themselves not to introduce new tax measures which are harmful within the meaning of the Code. They also have committed themselves to re-examining their existing laws and established practices. In this context the Code of Conduct establishes a formal review process - Member States have agreed to inform each other of existing and proposed tax measures which may fall within the scope of the Code; any Member State may request the opportunity to discuss and comment on the tax measure of another Member State that may fall within the scope of the Code; a Group has been set up by the Council to assess the tax measures that may fall within the scope of the Code and to oversee the provision of information on those measures. The Council has also noted that some of the tax measures covered by the Code may fall within the scope of the provisions on state aid in Articles 92 to 94 of the EC Treaty. Without prejudice to Community Law or to the objectives of the Treaty, the European Commission has published guidelines on the application of the state aid rules to measures relating to direct business taxation (see below). The Code refers to Member States co-operating more fully in the fight against tax avoidance and evasion, notably in the exchange of information between Member States, in accordance with their respective national laws. The Council also is of the view that anti-abuse provisions or countermeasures contained in tax laws and in double taxation conventions play a fundamental role in counteracting tax avoidance and evasion. The position of non EU countries The Code also refers to its geographical extension. Member States are committed to promoting in third countries the adoption of the principles aimed at abolishing harmful tax measures embodied in the Code. They are also committed to promoting their adoption in territories to which the Treaty does not apply. In particular, Member States with dependent or associated territories or which have special responsibilities or taxation prerogatives in respect of other territories have committed themselves, within the framework of their constitutional arrangements, to ensuring that the principles of the Code are applied in those territories. The Member States agreed to report to the Group set up to assess the tax measures on the position in the dependent territories which includes the Channel Islands and the Isle of Man. A report was submitted to the Code of Conduct Group at their meeting in November, and further consideration was given to that information at the Code of Conduct Group meeting in December. In the case of Jersey the list of potentially harmful tax measures submitted as part of the reporting arrangements include exempt companies, international business companies, international treasury operations and captive insurance companies. In the document presented on 17th November 1998 to the Code of Conduct Group, which is chaired by the United Kingdom Financial Secretary to the Treasury, the United Kingdom Government also tabled the following statement on the Island’s constitutional relationship with the United Kingdom - "The United Kingdom Government is responsible for the defence and international relations of Jersey, and the Crown is ultimately responsible for its good government. However the people of Jersey cannot vote in elections for the United Kingdom Parliament and it would be unprecedented for the United Kingdom to legislate for Jersey on taxation and other domestic matters without the agreement of the Jersey Authorities. Legislation on taxation matters has always taken the form of laws enacted by the Island legislature." This statement sets out the constitutional framework which the Insular Authorities had very much in mind when, at their request, the United Kingdom Government pressed successfully for the inclusion in the Code of Conduct of the phrase "within the framework of their constitutional arrangements". The Insular Authorities have also drawn attention to the statement made by The Rt. Hon. Geoffrey Rippon MP in November 1971 when he spoke to the States Assembly in St. Helier about the outcome of the negotiations for the entry of the United Kingdom into the European Community - "Under the proposals your fiscal autonomy has been guaranteed - I say that deliberately and slowly. There is no doubt whatever about that and I can say quite categorically that there will be no question of your having to apply a value added tax or any part of Community policy on taxation." Way ard The Code of Conduct Group produced an interim report to the ECOFIN Council [6] on 1st December. A second interim report is due to be presented to the Council in May 1999 followed by a final report in November 1999. The Code of Conduct Group is working through a list of around 80 corporate tax measures which may be "harmful". Sub working groups are focusing on two types of systems; intra-group services (essentially co-ordinating centres, distribution centres and service centres) and financial services and "offshore" companies, defined as those set up in another EU Member State. Initially national delegations have drawn up a description of each of the cases to be studied, and steps are now being taken to try to establish whether or not these cases meet the five criteria set by the Code of Conduct to assess the harmful nature of a measure, ie: whether the advantages are only granted to non residents; whether they are totally isolated from the domestic economy; whether they are granted even in the absence of any real economic activity in the country granting these advantages; whether the rules determining the profits of the internal activities in a multinational group differ from the principles admitted at international level; and whether the fiscal measures lack transparency. Final decisions on which tax regimes are deemed to be "harmful" and which should be banned within the European Union will not be taken until all five categories have been examined. Taxation of savings income In May 1998 the European Commission presented to the Council of Ministers a new proposal for a directive to ensure minimum effective taxation of savings income within the European Union. The proposal seeks to tackle economic distortions within the Single Market arising from non-taxation of cross-border interest payments to individuals. The Commission proposal is based on a "coexistence model", whereby each Member State would have to apply either a withholding tax of at least 20% or to provide information to other Member States on interest income from savings. In presenting this proposal the Taxation Commissioner Mario Monti stated "Once adopted by the Council, this measure will remove a significant distortion in the Single Market. It will also contribute to Member States’ efforts to achieve a more balanced tax burden between capital and labour which would in turn favour job creation." Under the proposal, and depending on the choice adopted by the Member State in which interest covered by the directive is paid, the individual who places his savings in another Member State would know that either the tax authorities in his home State would be informed about the interest received or he would receive the payment of interest reduced by the withholding tax. He could, however, choose to notify his home State about the interest on his savings in another Member State. He could then apply for a certificate attesting to this notification from his tax authorities and the institution paying the interest would levy no withholding tax on the interest if provided with this certificate. The proposed directive does not seek total harmonisation of the taxation of interest income within the EU. The proposal only covers the taxation of cross-border savings income in the form of interest paid from one Member State to individuals who are resident in other Member States. The Commission in its explanatory memorandum attached to the draft directive indicates that the scope for non-taxation of cross-border interest payments in the Community is the cause of economic distortions which are incompatible with the proper functioning of the Single Market. In the view of the Commission, the European financial area, the creation of which was made possible by the liberalisation of capital movements, cannot deliver all its benefits if savers’ decisions are determined by the possibility of avoiding tax instead of a comparison between investment alternatives based on their intrinsic merits. The need for joint action to eliminate these economic distortions is rendered all the more urgent, in the view of the Commission, by the start of the third stage of economic and monetary union, which will further facilitate the cross-border investment of savings. Furthermore it is considered that the budgetary discipline required of Member States also means that any erosion of tax bases linked to the absence of guarantees concerning a minimum of effective taxation on the cross-border investment of savings is becoming less and less acceptable. Against this background, the absence of guarantees concerning a minimum of effective taxation on the cross-border investment of savings is also said to be hindering Member States’ efforts to restore the balance in terms of the burden of taxation between the different factors of production and thereby to achieve a reduction in the level of total taxation on income from employment, something which it is believed would have a favourable impact on job creation and the fight against unemployment. Because the taxation of income from savings will only apply where the beneficial owner is an individual who receives interest in his own right, interest payments made for the benefit of legal persons or companies, as well as those made to individuals who receive them in a professional capacity as agent, or trustee or nominee for another person, will be outside the scope of the directive. The position of non EU countries The draft directive would also apply only where the interest payment is made to an individual who is a resident of another Member State. Where payments are made to those resident in third countries the directive will not apply. Where the interest payment is made by a number of intermediaries, possibly established in different countries or territories, the directive only covers the transaction whereby interest is paid for the immediate benefit of the beneficial owner where that person is resident in a Member State. It would appear therefore that if payments are made from a Member State to an intermediary in a non EU country which intermediary then subsequently makes payment to an individual resident in the European Union, the withholding tax requirement would not apply. It is for these reasons that the Council of the European Union, in its conclusions of 1st December 1997 on the taxation of savings, considered that the provisions of the directive should take into account the need to preserve the competitiveness of European financial markets and indicated that the basic principle needed to be adopted as widely as possible. To this end the Council decided that the Community should enter into negotiations with its main third country commercial partners, either bilaterally or multilaterally, to ensure the effective taxation of savings income covered by this directive which is paid to residents in the Member States by paying agencies established in those third countries. The Member States have also agreed to undertake, towards the same end, to promote the application of provisions equivalent to those of the directive in territories which do not fall within the scope of the directive. In particular, Member States which have dependent or associated territories or which have particular responsibilities or taxation prerogatives in respect of other territories are requested to undertake, where appropriate within the framework of their constitutional arrangements, to ensure that measures equivalent to those of the directive are applied in those territories. However, the decision of the Council of the European Union to promote the adoption of measures equivalent to those of the directive in third countries as well as in Member States’ dependent or associated territories is not included in the directive but in an annex to the directive. This is because it is understood that a requirement to promote the adoption in third countries of equivalent measures relating to payments of interest to Community residents can only be achieved through voluntary means and not through European Community law. The annex of the main proposal represents a political commitment by the Member States, and the directive itself will only be applicable in the Member States of the European Union. The draft directive, if adopted, will not apply to the Island as it falls outside the scope of Protocol 3 of the Treaty of Accession of the United Kingdom to the European Community which defines the Island’s relationship with the Community. In common with other non-applying directives or regulations any extension to the Island will be for the Insular Authorities to determine having regard to their assessment of their best interests. The Insular Authorities have also underlined that, while the European Union can make a statement to the effect that it is hoped that the measures covered by the draft directive will be adopted by the dependent territories of the Member States, this statement cannot override the terms of Protocol 3 nor the independent position of the Island on matters of taxation. The Insular Authorities, in considering their response to any decision of the European Union to implement a withholding tax on savings income, will have regard for, among other things, the position being adopted by other non EU countries. The Insular Authorities would expect the European Union also to recognise the likely impact on their capital markets if any change in the Island’s tax structure was to result in funds presently attracted to Jersey from the world at large being diverted to financial centres further afield whose business links are more with the American or Far Eastern capital markets. Other EC proposals In March 1998 the Commission presd a proposal on the taxation of royalty and interest payments between companies [7] which is designed to remove the double taxation of such payments between companies. The Commission has called on the Council to set a deadline to reach concrete results by the end of June 1999. In November 1998 the Commission also published guidelines clarifying how it will apply State aid rules in the field of direct business taxation. The Commission in its notice on the application of the State aid rules to meas relating to direct business taxation [8] has referred to the fact that the EC Treaty empowers the Community to take measures to eliminate various types of distortion that harm the proper functioning of the common market. Some general tax measures, it is stated, may impede the proper functioning of the internal market. In the case of such measures the Treaty provides, on the one hand, for the possibility of harmonising Member States’ tax provisions on the basis of Article 100 (Council directives, adopted unanimously). On the other hand the Treaty provides that disparities between planned or existing general provisions in Member States which may distort competition may be eliminated on the basis of Articles 101 and 102 (consultation of the relevant Member States by the Commission; if necessary, Council directives adopted by a qualified majority). Article 92(1) of the EC Treaty states that "any aid granted by a Member State or through State resources in any form whatsoever which distorts or threatens to distort competition by favouring certain undertakings or the production of certain goods shall, in so far as it affects trade between Member States, be incompatible with the common market." In applying the Community rules on State aid, it is irrelevant whether the measure is a tax measure, since Article 92 applies to aid measures " in any form whatsoever." For a measure to be termed "aid", it must confer on recipients an advantage which relieves them of charges that are normally borne from their budgets. The advantage may be provided through a reduction in the firm’s tax burden in various ways, including: -
a reduction in the tax base (such as special deductions, special or accelerated depreciation arrangements or the entering of reserves on the balance sheet); -
a total or partial reduction in the amount of tax ( such as exemption or a tax credit); -
deferment, cancellation or even special rescheduling of tax debt. For a measure to be termed "aid", the advantages must be granted by the State or through State resources; the measure must affect the competition of trade between Member States; and the measure must be specific or selective in that it favours certain undertakings or the production of certain goods. The selective advantage may derive from an exception to the tax provisions of a legislative, regulatory or administrative nature or from a discretionary practice on the part of the tax authorities. OECD report on harmful tax competition At its April 1998 Ministerial meeting the OECD on a series of recommendations to counter the spread of tax havens and harmful preferential tax regimes. These recommendations were contained in a report entitled "Harmful tax competition: an emerging global issue" issued by the Committee on Fiscal Affairs. [9] One aspect of this political mandate is to create an OECD list of tax havens by October 1999. This reflects the feeling among OECD countries that in the new world of liberalised financial markets tax havens need to reconsider their rôle. To implement the mandate, the Committee on Fiscal Affairs, which is the main tax policy body of the OECD, has created a "Forum on harmful tax practices." Luxembourg and Switzerland have abstained from the approval of the report and the adoption of the recommendations. The OECD report is intended to develop a better understanding of how tax havens and harmful preferential tax regimes, collectively referred to as "harmful tax practices", affect the location of financial and other service activities, erode the tax bases of other countries, distort trade and investment patterns and undermine the fairness, neutrality and broad social acceptance of tax systems generally. It is suggested that such harmful tax practices diminish global welfare and undermine taxpayers’ confidence in the integrity of tax systems. The report is in three parts. Chapter one provides an overview of the basic principles underlining the existing international taxation arrangements and the ways in which the process of globalisation has put pressure on these arrangements. Chapter two analyses the factors that can lead to conclusions that tax havens and certain preferential tax regimes are harmful and presents the concerns that OECD Governments have about the impact of such regimes on the integrity of their tax systems. Both transparent and non-transparent regimes are covered. Chapter three recommends some measures that can be used to counteract tax havens and harmful preferential tax regimes. These measures, it is suggested, can be taken through domestic legislation, in tax treaties and in the context of intensified international co-operation. The Chapter also sets out the guidelines on harmful preferential tax regimes and a procedure to identify tax havens and proposes the creation of a Forum on harmful tax practices under the auspices of the Committee on Fiscal Affairs. The report has been criticised because it is limited to financial activities and excludes industrial and commercial activities, and therefore is said to adopt a partial and unbalanced approach. Critics have also made the point that insufficient regard is had for the fact that a degree of competition in tax matters can have positive effects. There has also been criticism of the way in which the provisional list of tax haven jurisdictions has been compiled. It is suggested by the OECD that the jurisdictions included on the provisional list are those whose names appear frequently on published lists of tax havens, but the omission of a number of jurisdictions that would appear in such published lists would suggest that some other criteria have been used in finalising the list. There are 47 jurisdictions on the provisional list (including the Channel Islands and the Isle of Man) but excluded from that number are Dublin, Hong Kong, Labuan, Luxembourg, Madeira, Singapore and Switzerland. The OECD report draws a distinction between three broad categories of situation in which the tax levied in one country on income from geographically mobile activities, such as financial and other service activities, is lower than the tax that would be levied on the same income in another country: -
the first country is a tax haven and, as such, generally imposes no or only nominal tax on that income; -
the first country collects significant revenues from tax imposed on income at the individual or corporate level and its tax system has preferential features that allow the relevant income to be subject to low or no taxation; -
the first country collects significant revenues from tax imposed on income at the individual or corporate level but the effective tax rate that is generally applicable at that level in that country is lower than that levied in the second country. The report recognises that the concept of "tax haven" does not have a precise technical meaning. However it is stated that a useful distinction may be made between, on the one hand, countries which are able to finance their public services with no or only nominal income taxes and are offering themselves as places to be used by non residents to escape tax in their country of residence and, on the other hand, countries which raise significant revenues from their income tax but which have tax systems having features which constitute harmful tax competition. Those jurisdictions that fall into the first category are referred to as "tax havens" and those jurisdictions that fall into the second category are considered as countries which have potentially harmful preferential tax regimes. The Forum established by the Committee of Fiscal Affairs is mandated to establish within one year of the first meeting of the Forum (ie around October 1999) a list of tax havens on the basis of the factors identified in the report. The key factors in identifying tax havens are stated to be - (a) no or only nominal taxes No or only nominal taxation on the relevant income is a starting point to classify a jurisdiction as a tax haven. (b) lack of effective exchange of information Tax havens typically have in place laws or administrative practices under which business and individuals can benefit from strict secrecy rules and other protections against scrutiny by tax authorities, thereby preventing the effective exchange of information on taxpayers benefiting from the low tax jurisdiction. (c) lack of transparency Lack of transparency in the operation of the legislative, legal or administrative provisions is another factor in identifying tax havens. (d) no substantial activities The absence of a requirement that the activity be substantial is important since it would suggest that the jurisdiction may be attempting to attract investment or transactions that are purely tax driven. The OECD’s report also identifies the factors that may help identify harmful preferential tax regimes without targeting specific countries. Four key factors are considered to assist in identifying harmful preferential tax regimes; -
the regime imposes a low or zero effective tax rate on the relevant income; -
the regime is "ring-fenced"; -
the operation of the regime is non-transparent; -
the jurisdiction operating the regime does not effectively exchange information with other countries. A harmful preferential tax regime will be characterised by a combination of a low or zero effective tax rate and the other factors referred to above. Other factors are also considered to assist in identifying harmful preferential tax regimes, other than the key factors referred to above. These are - -
an artificial definition of the tax base; -
failure to adhere to international transfer pricing principles; -
foreign source income exempt from residence country tax; -
negotiable tax rate or tax base; -
existence of secrecy provisions; -
access to a wide network of tax treaties; -
regimes which are promoted as tax minimisation vehicles; -
the regime encourages purely tax-driven operations or arrangements. The OECD report concludes with recommendations for counteracting harmful tax competition. These recommendations fall into three categories: -
recommendations concerning domestic legislation; -
recommendations concerning tax treaties; -
recommendations for intensification of international co-operation. The recommendations concerning domestic legislation and practices are designed to encourage countries to adopt rules relating to foreign controlled corporations, and to restrict exemption on foreign income from domestic taxation. Recommendations concerning tax treaties refer to the greater and more efficient use of exchanges of information, to the tightening up of provisions for entitlement to information, and to terminating tax conventions with tax havens. Recommendations to intensify international co-operation in response to harmful tax competition include endorsing the guidelines on harmful preferential tax regimes; establishing a Forum to implement the guidelines and other recommendations in the report; and mandating the Forum to establish a list of tax havens. It is also recommended that countries that have particular political, economic or other links with tax havens ensure that these links do not contribute to harmful tax competition and, in particular, that countries that have dependencies that are tax havens ensure that the links that they have with these tax havens are not used in a way that increase or promote harmful tax competition. The Forum is also to engage in a dialogue with non member countries with the aim of promoting the recommendations in the report. In respect of the guidelines for dealing with harmful preferential tax regimes in member countries, these include a reference to removing, before the end of five years starting from the date on which the guidelines are approved by the OECD Council, the harmful features of member countries’ preferential tax regimes. In respect of taxpayers who are benefiting from such regimes on 31st December 2000 the benefits that they derive are expected to be removed at the latest by 31st December 2005. As noted above, both Luxembourg and Switzerland have stated that they will not be bound by the report or by the recommendations to counteract harmful tax competition. The Insular Authorities have made representations to the OECD in response to their invitation to comment upon the report including the provisional list of tax havens. The OECD are currently engaged in evaluating Jersey’s submission and it has been indicated that the Insular Authorities will have an opportunity to make further representations in due course. The OECD Forum on harmful tax practices will undertake a review of the tax regimes of each of the jurisdictions on the provisional OECD tax haven list. For this purpose the Forum has set up four study groups. Each study group will be led by the Committee on Fiscal Affairs Chairman and one of the four countries (France, Ireland, Japan or the US) that comprise the Bureau of the Forum. Each study group will also include two or three other OECD countries and the Secretariat. Each study group will examine the information provided by the relevant jurisdiction and, where necessary, request additional information or clarification. When a study group has completed its review it will produce a jurisdiction report which will be submitted to the full Forum. The judgement whether a jurisdiction is a tax haven will be made by the Forum in a plenary session on the basis of an overall assessment of the jurisdiction’s tax regime. However, before a study group submits a jurisdiction report to the Forum the jurisdiction in question will be given the opportunity to comment on the information in the completed report. The Insular Authorities have argued that the key factors used to identify a tax haven, as set out in the OECD report, do not apply to Jersey for the following reasons - -
Jersey does not generally impose "no or only nominal" taxation. The standard rate of tax of 20% has remained unchanged since 1940 and provides 90% of the Island’s tax revenues; -
the Island does not have a bank secrecy law. The Island also has legislation already enacted or in immediate prospect that is more extensive than the legislation of many OECD member countries in providing for the effective exchange of information on those engaged in crime; -
there is no lack of transparency in the operation of the Island’s legislative, legal or administrative provisions. This statement has been reinforced by the recently published Edwards Review of financial regulation in the Island; -
the major part of business activities in the Island are of a substantial nature. The Insular Authorities have argued that Jersey can be equated to Switzerland and Luxembourg neither of which is on the provisional list of tax havens. G7 Countries Communiqué The G7 countries met in London in May 1998 and warmly welcomed the OECD agreement on action to tackle harmful tax competition. The Communiqué noted that this provided a strong basis for co-ordinated international action to curb harmful tax competition through preferential tax regimes and tax havens, and the G7 countries also noted the complementary development of the EU Code of Conduct. The Communiqué welcomed the establishment of the OECD Forum on harmful tax practices and actively supported the proposed dialogue with non-OECD members to promote the agreed principles and recommendations on a global basis. The Communiqué urged the OECD to give particular attention to the development of a comprehensive programme to improve the availability of information to tax authorities to curb international tax evasion and avoidance through tax havens and through preferential tax regimes. This, it was stated, would involve developing further the proposals to improve exchange of tax information between OECD countries in order to address the problems caused by restricted access to banking information and to improve the supply of information from tax havens by the negotiation of effective information exchange arrangements. Conclusion There has undoubtedly been a change in the international climate and an increased determination to tackle "harmful" tax competition. In due course Jersey in common with the world at large, will be called upon to respond to this change in climate. However, it can be expected that all countries will wish to continue to see taxation policy as a matter for national governments to decide, and will wish to have regard for the need to safeguard the economic well-being of their residents, recognising the damage that could be caused to their economies if there is inconsistency in the action taken by other countries and in particular by their main competitors. In common with this, the Insular Authorities before deciding how to respond to the change of climate in respect of tax competition will require proper evidence that full regard is being had for a level playing field internationally with no significant differences in interpretation from one country to another. Colin Powell OBE was Economic Adviser to the States of Jersey between 1969 and 1992 and was Chief Adviser to the States of Jersey until December 1998 ___________________ Footnotes - (Top) [1] - OJC 002/1, J [2] - OJC 212/13, th, 1998 [3] - Report by the Committee on Fiscal rs presented to Ministers of the OECD countries at their Council meeting on April 27th/28th, 1998 [4] - The communiqué, described as a major new initiative ckle harmful tax competition, was issued by G7 Finance Ministers following a meeting in London on May 9th 1998 [5] - OJC 002/1, Janth 1998 [6] - ECOFIN - The Economic and ce Council of Ministers [7] - OJC 123/9, 22nd, 1998 [8] - OJC 384ecember 10th, 1998 [9] - Report presented to Ministers of OECD countries at their Council meeting on April 27th/28th, 1998 |