On-demand seminar - Ireland: A new gateway to Europe

Scott: Let me take a minute to introduce you to our co-sponsor today. Mason Hayes Curran is one of the largest business law firms in Ireland. Their areas of expertise include M&A, securities, tax, finance, financial services and litigation, in which areas they are objectively ranked as one of, if not the top, law firm in Ireland. Motivated by what was seen by us as an increasing level of interest on the part of Canadian businesses in Ireland, not only as a gateway to Europe, but as a great place to do business, together with the Mason Hayes Curran firm we decided that the time was right to pull together a group of experienced business people, and experts, to talk about doing business in Ireland.

With that let me introduce you to representative of your host firm, Emer Gilvarry. Emer is the chairperson of Mason Hayes Curran and in her own right is a formidable leader of the legal profession in Ireland. Emer.

Emer: Good morning everyone and thank you for that introduction, Minister, Ambassador. Thanks so much to everyone for being here this morning. It's wonderful to see a full room. Thank you in particular to Scott and the Gowling WLG team who put in an awful lot of effort into this program. It is about timing. I suppose Canada and Ireland are two of the most outward facing economies that we have in the world. We find ourselves in a strange place because our respective largest trading partners, and our next door neighbours, are taking a different path of travel. They're looking to internalize, or at least that's what we think they're doing, and they're looking away from globalization. We need to look at that as an opportunity. Some people might call it a challenge but Irish people are really good at taking up a challenge. I think we found that out and we learned a lot about ourselves when we went into a deeper session in 2008. Your heads were down for a while and I was reminded many times about what WB 8 said about the Irish when he said, "Being Irish we have a deep sense of tragedy which sustains us to temporary moments of joy." But you know something? We picked up that ball and we got back on the pitch and we now have an even stronger more diversified economy. We kept doing what we do best. And that is attracting and retaining business in Ireland because it's what we're good at. I know what Brexit people say, "There's lots of opportunity for Ireland." We've been taking those opportunities for decades. We're good at bringing people into our economy and into our society. The parallel discussion this morning therefore is very timely, very relevant, very current. But before we get to that, we are honoured to have our keynote speaker here this morning, Minister Coveney. I am going to invite the Irish Ambassador to Canada, Ambassador Jim Kelly, to join me now to introduce our keynote speaker. Ambassador Kelly.

Ambassador: Thank you very much Emer. Good morning to everyone, Minister, Ladies and Gentlemen. I want first to congratulate our host, Gowling, and their event partners, Mason Hayes Curran, IDA Ireland and the Ireland Canada Chamber of Commerce here in Toronto, for putting this event together today on the theme of "Ireland - A New Gateway to Europe". We, in the Irish Embassy, are also delighted to be associated with this morning's breakfast and as well to see such a strong turnout of companies and business people from a wide range of sectors here. When my colleague Emmanuel Dowdall, from IDA Ireland in New York, asked me to participate here this morning awhile back I was delighted to accept. For me, as a relatively new Ambassador, I'm about six months here in Canada, the theme of the unique opportunity that Ireland offers to Canadian business, at this moment of change and challenge in the world, has been a central part of my message in my own engagement with business and government interlocutors across Canada. I saw this morning's event as an excellent opportunity for me to explain to you as business people why there's never been a better time to invest in and trade with Ireland. I know of course that business people like nothing more than opportunity but I know that they never say no to an upgrade either. When we heard that we would have a senior government Minister in town this week, ahead of St. Patrick's Day, we felt sure that you would appreciate hearing his personal views and insights on the theme of today's breakfast. We're delighted that he's agreed to be with us here this morning to share his thoughts with all of you.

Let me briefly introduce him to you. The first thing to mention is that Minister Simon Coveney is from Cork. If you know Cork you will appreciate how important that is in the scheme of things in Ireland. He was first elected to the Irish Parliament in 1998 as one of his Fine Gael party's youngest TD's, or Members of Parliament. Rising over the course of his parliamentary career to serve from 2011, first as Minister for Agriculture, where he drew on his own academic background in agriculture and land management, and was appointed Minister for Defense also in 2014. With the return of a Fine Gael government following the 2016 election, Minister Coveney was appointed Minister for Housing, Planning and Local Government. A complex portfolio which includes responsibility for a number of sectorial areas key to the long term health of the Irish economy. With Brexit looming as both a major challenge and an opportunity for Ireland over the coming years, Minister Coveney also brings valuable direct experience of the European Union and its institutions. Following a term as a member of the European Parliament from 2004, during which time he served on both the Parliament's Foreign Affairs Committee and its Internal Market and Consumer Protection Committee. Minister Coveney brings, I think, a unique combination of experience and insight, both domestic and European, to the theme of this morning's discussions. Without further ado, I'd like you all to give a very warm welcome to Ireland's Minister for Housing, Planning and Local Government, Simon Coveney.

Minister: Thank you, Ambassador. Thanks Jim. Thank you Emer, as well, particularly for that nice quote, which I think kind of sums up the Irish. They like to be miserable but actually find ways of being joyous as well. I'm particularly pleased to be here and this is the first event I'm at. My own family is very much affected by Irish immigration to Canada. I'm married to one of 12 children, seven of whom are in Canada, five in Toronto, one in Vancouver, one in Victoria and her uncle actually was the longest serving Mayor of Port McNeill and built a big building and logging business there. This is a country that we as a family have real closeness too. It's a privilege as a Minister to be here and the buildup to St. Patrick's Day. Thank you for those of you who have already started to find green ties to wear them this morning. It's appreciated. Mine comes out once a year too. As I say, it's a pleasure to be here with you this morning to offer an Irish Government perspective on the topic of today's forum, which is Ireland - A New Gateway to Europe. Before I address the topic I want to congratulate the organizers. Our hosts, Gowling WLG, and their partners for today's event the Irish legal firm, Mason Hayes Curran. Who I know well in Ireland and who I would strongly recommend to any of you who need legal advice or assistance in the context of Irish Canadian Business. I also want to thank, of course, the Ireland Canadian Chamber here in Toronto, the IDA, Enterprise Ireland who are here, Tourism Ireland who are here and of course, the Embassy, through Jim.

The initiative which you've taken has brought us together this morning for an important and timely discussion. Discussion on what Ireland has to offer Canadian companies seeking a new gateway to Europe and I'm delighted to see a number of significant investors in the Irish economy will be speaking to you also later on. It's important because we know that there are considerable challenges but also opportunities for Ireland and Canada working together. It's timely because we're on the cusp of seeing a 98% of our bilateral trade liberalized by a landmark EU Canadian Comprehensive Economic Trade Agreement, or CETA, as you all know it. That can help us unlock that potential by offering Irish and Canadian companies a boost of a new competitive advantage in each other's markets. The specific opportunity which CETA offers our two countries should also be considered against the backdrop of an ever more challenging international trading environment. We have to acknowledge that we both live and trade in very uncertain times. Canada's largest trading partner and its closest neighbour, the United States, has recently expressed its intention to reopen NAFTA. It has even spoken of introducing new border taxes on imports. Meanwhile, Ireland's largest trading partner and closest friend, the UK, has also chosen to leave the European Union and will do so, or start the process of formally doing so in the coming days. This is a huge decision for the UK but it's also a huge decision for Ireland. For all sorts of reasons that many of you who come from Ireland would understand. Faced with these challenges both of our countries have an opportunity to seek support with each other and opportunities in the context of outward looking international trade. Canada and Ireland need look no further than each other in this context. From an Irish perspective the opening provided by CETA could not have come at a better time. The ups and downs of the Irish economy over the past decade are well documented and I've already been referred to it.

I would like to say a few words about the Irish economic situation so that you're clear on where Ireland is at right now. As you know we have come through a very difficult period. In the wake of an international financial crisis the government was forced to take a series of very tough decisions to repair our economy and place our public finances back on a sustainable footing. This was a difficult task which necessitated great sacrifice on behalf of many people. But's now complete and a strong and sustainable economic recovery is now firmly established. All key economic indicators point to continued solid economic growth in Ireland. Despite a challenging regional and global environment, we have had the fastest growing economy in the European Union for the last two years, and may well have so again in 2017. We are predicting at least 3.5% GDP growth this year. This growth is broad based and our economic fundamentals remain robust. Exports have grown strongly while the domestic economy is now driving growth with private consumption up by over 3% in the first three quarters of last year. Employment has increased in every quarter over the last four years. The total numbers of jobs has increased by over 200,000 since mid-2012 and there's now more than two million people at work. As many as there ever have been in Ireland. In February the unemployment rate stood at 6.6%. If you look back six years that figure was close to 16%. That just shows you the pace of change and progress in terms of economic opportunity. For anyone seeking an investment base in Europe it is a very different Ireland to that which you have read about in the post 2008 period. With business facing a complex and uncertain world Ireland offers you a stable, competitive, secure and very pro-business economy with a well-educated and productive workforce and a reputation for excelling in research and creative discovery. The market's recognize this too. The cost to us of borrowing an international markets is close to historic lows. Irish bond deals are trading in line with European sovereign bonds. The yield an Irish government 10 year bonds is trading steadily at close to 1%. We have regained an "A" grade status from all major sovereign debt rating agencies. Against this backdrop the number of new investments secured in Ireland in 2016 rose by 14.6% to 244, in spite of global economic uncertainty, intense competition from other jurisdictions and a changing global taxation landscape. Over 40% of these were new name investments. Our stable business environment and our certain access to EU markets mean that we remain extremely well placed to win new FTI investments in Europe. To all of this, our continued membership of the European Union is absolutely critical. So what then of the UK's decision to leave the EU? What will it mean for Ireland in terms of both challenges and opportunities?

Let me begin by saying that we regret the UK's decision to leave the European Union. Though we respect, of course, their decision. We have long been conscious of the potential implications for Ireland of a Brexit and have been proactive in identifying and prioritizing those challenges. Readying ourselves to meet them and work hard to build a high degree of understanding among our EU partners for those particular priorities. Over the past two years we have conducted a detailed analysis of the likely impact of Brexit on Ireland. We are clear on what's involved across some 11 working groups. In what is a whole of government approach we have identified risks, mitigation measures and opportunities for us arising out of Brexit. Each of these are being pursued. Our key priorities, including preserving our strong bilateral trade relationship with the UK, the maintenance of the common travel area between our two countries and, critically for the whole of Ireland, the preservation of a hard won achievement of the Northern Ireland peace process and ensuring no return to hard borders on our island. While we know that Article 50 is likely to be triggered this week, that is really just the start of a two year process that Ireland needs to be central to, in terms of those negotiations on the European Union negotiating side. A fourth area of priority for us is to influence the future of post Brexit EU. The fundamental point to note here is that the future of the European Union matters to Ireland because it's our future too. I want to emphasize it because this basic fact has at times been misconstrued in international reporting of the Brexit issue. Including here in Canada. Let me be very clear on this. Ireland will be participating in these negotiations as a member of the European Union and we will in all circumstances continue to be a committed member to the EU in the future. We understand, very clearly, that EU membership is overwhelmingly in our national interest, politically, economically and socially. Our membership in the European Union has provided the foundation for much of the dramatic economic and social progress which Ireland is made over the last four decades or so. Membership of the single market and the customs union remains fundamental to our success in attracting inward investment and helping Irish companies to diversify and grow their export markets. As a small country whose values and interests converge in support of a rules base, multi-lateral order. The EU continues to provide us with the essential means to protect our foreign policy priorities alongside likeminded partners. Even as we seek to manage the challenges which Brexit would pose for Ireland we reject any notion that this will require making a choice between the EU and the UK. This is the view, not only of the government, but also of the wider public in Ireland, where surveys regularly show that more than 80% support continued membership of the European Union post Brexit. So while the UK is our closest neighbour, and as I said earlier, in many ways our closest friend, we are going to remain in the European Union and we will help them, I hope, in the future to develop and maintain a close relationship with the European Union as a whole, but in particular, with Ireland.

A crucial look at the Ireland/UK trade relationship helps to explain why we need to balance our support for membership of the European Union but also maintain a close relationship with the UK. And the UK joined the then EEC at the same time in 1973. At that time the UK counted for 55% of all Irish trade. We were heavily dependent on the UK. But our membership of the European Union has brought us enormous benefits. Not least of which has been our access to a single market, of today some half a billion people. It has enabled us to develop structurally and economically and diversify our trade relationships significantly. Today, 40% of our Irish trade is now with all other EU member states compared with 14% with the UK. Brexit still represents significant challenges for us, in this regard, given the relative concentration of SME exports to the UK market. Particularly from my previous brief which was agriculture and food. It is important to see these challenges to in a wider context of our growing trade with Europe, and in deed, the rest of the world and I hope to an increasingly level with Canada. When Article 50 is triggered by the UK Prime Minster, Ireland will be part of team EU in the negotiations and, moreover, we will be keen to maintain unity among what will be, at the time, an EU 2027. We will work for solutions which meet our specific challenges and minimize the damage to our political and economic interests in the context of the UK's departure. Even as we seek to minimize these costs our government will continue to take measures to mitigate the potential impact of our economy and help make Ireland, what's becoming known as, Brexit ready. Having prepared ourselves properly we will bring a calm and constructive approach, I hope, to the negotiations. Which even before they've started, in many ways, have attracted unnecessarily aggressive language on both sides. We have no wish to see anybody punished. Our overall interests lie in our membership of a vibrant and successful European Union which maintains the closest possible relationship with a stable and prosperous and outward looking United Kingdom. As an EU member, and a close friend and neighbour, we will work very hard to maintain the closest possible relationship with our British friends and to ensure a strong EU/UK relationship and a well-managed and orderly UK withdrawal from the Union.

Then of course there are the opportunities. As a committed member of the eurozone, as well as the EU, with a highly educated English speaking population, a business friendly environment and a common law tradition, we would be keen to maximize the opportunities in terms of attracting new jobs and investment. Looking at those attributes I believe that we offer a particularly compatible business environment for Canadian companies who face decisions on new investments or on relocation of existing operations for investments.

On the other side we're focused on a Brexit related diversification of exports to other key markets. The arrival of CETA will heighten our focus on Canada as one of those key markets. The government plans to send a ministerial trade mission to Canada in late May/early June to spearhead this effort. In more specific terms, what does Ireland offer new investors? That, after all, it is the question I think, from many of the companies that are represented here this morning. We have a strong pool of highly skilled multi-lingual workers in the only English speaking country within the eurozone providing barrier free access to an EU market of, as I say, nearly half a billion consumers. 40% of our population is under the age of 29. It's the youngest population in the European Union. Our education system ranks in the top 10 in the world and over 50% of Irish 30-34 year olds have a third level degree. Higher than in any other country in the European Union. Ireland offers a pro-business environment together with a stable and competitive corporate tax regime and strong incentives for research and development. We have maintained our position as the best country in the eurozone for doing business in the Forbes magazine ranking in 2016, coming overall fourth in the world. This ranking is testament to Ireland's favourable business climate and regulatory climate. We are one of the most competitive economies in the world. Competitiveness gains have been sustained as the economy grows strongly with inflation below the EU average since 2008. Our improved competitiveness position is reflected in global competitiveness reports. The IMD ranks us first in the eurozone, fifth in the OACD and seventh in the world for overall competitiveness. Ireland is one of the most productive economies in Europe. Irish labour, productivity is almost 35% above the EU 27 average. Ireland is ranked first in the world for the flexibility and adaptability of people. First for finance skills and third in the world for productivity of companies and workforce productivity. This being the case Ireland is increasingly home to international talent. With an overall proportion of 15% Ireland is the third highest international workforce in Europe. 11% of workers come from other EU countries.

Perhaps it's not surprising therefore that Ireland is home to nine of the top 10 global software companies. nine of the top 10 US technology companies. All of the top 10 born on the internet companies. Nine of the top 10 global pharmaceutical firms. I live next to one of the largest pharmaceutical hubs of the world, around Cork harbour. 15 of the top 20 global medical technologies companies. The market speaks for itself and Canadian investors have been an important part of that success story. Canadian investment in Ireland is estimated at about 14 billion Canadian dollars. Major investors today include Great-West Life, who purchased Irish Life in 2013, Couche-Tard who have acquired the Topaz chain and Irving Oil, who last year acquired the Whitegate Refinery. I was there that day and what a fantastic family story that has grown out of Canada which is now becoming a global player in relation to oil and refining. We hope that many more Canadian investors will follow their successful footsteps and Canadian access to our markets will undoubtedly be helped further by the entry into force of CETA. Canadian and EU businesses will now compete on a truly level playing field by removing almost all the customs duties which importers have had to pay on exported goods. CETA will benefit exporters and investors as well as consumers. CETA will create jobs on both sides of the Atlantic. I can say to you that I'm here as somebody who really values the Irish/Canadian relationship? It's one of extraordinary generosity on behalf of Canada as a country. We have seen tens of thousands of young Irish men and women come to Canada and build a life here, and I hope, help to build a better country here with many people in this room. That continues, and has continued in particular since 2008 in the most recent past, where we've seen about a hundred thousand young Irish people come to Canada to work here. Just to put that into context that is the population of Ireland's third largest city. Choosing to come to Canada to be part of the four and half million who call themselves Irish-Canadian or Canadian-Irish. We can build on that relationship in a way that opens up the doors to economic business opportunities. We can learn from each other. Ireland's not perfect and I'm sure we'll hear from the investors, in a few minutes time, about the good and the bad and the challenges of growing business in Ireland. But I do think our record speaks for itself. There are very few companies come to Ireland to build platforms for international trade and growth that choose to leave again. Very, very few. Most of them end up growing and expanding and employing many, many more people there from what they had intended to do when they come in. I regard the relationship with new companies that come to Ireland as a partnership, not only from a business perspective with the partners that you choose to do business with, but actually a partnership with the Irish state, including government. So that we ensure that those business decisions, and that appetite for risk to come to Europe and use Ireland as your gateway into Europe, is actually the success story that you hope it will be. Thank you very much for taking the time to listen to me to this morning and I look forward to your questions if you have any.

Ian: Thank you Scott and thank you Minister and Ambassador. That was terrific overview of the future of opportunities for Ireland. I want to invite up some folks that I've got to know quite well here. Gentlemen, why don't you come up and join us here. I'll just introduce you as you come up. We have the benefit, now, of learning about some businesses that are active in Ireland today, that regardless of what happens to CETA and Brexit and NAFTA, and what other acronym you want to throw out there, these are gentlemen who their organizations are actively carrying on businesses in Ireland today. They're Canadians. They're based here and they've got some interesting stories to tell. What I'll do is I'll briefly introduce. Their more detailed bios are in the materials that you've already got and then we'll let them introduce their organizations, briefly, so you can get a sense of what they've been up to. In brief, the three gentlemen here, in the middle we've got Jay Haynes, who's a professional engineer with over 25 years entrepreneurial track record in various companies, but he's currently with a company called eSentire which is based in Cambridge, Ontario. In the time that he's been there since 2010 they've grown by more than 20 times their size. He's a recognized and respected and reliable voice on topics with respect to cyber security throughout North America and throughout Europe as well. He's going to talk to us a bit about eSentire. To his right, is David Ehrlich. David is a lawyer by training. He's currently the CEO of Irish Residential Properties Reit, "I•RES", but he's got a long history of experience in practicing law within Stikeman Elliott, one of the firms that I deal with on a regular basis. Then, finally, to my immediate right is Christian Kargl-Simard who is, relatively recently, the CEO of Adventus Zinc, which is now a listed company here and has zinc development assets in both Canada and Ireland. I'll let him walk through details. He's spent many years as investment banker before that and is also a mining executive. He too is a professional engineer and did his degree at UBC. So we've got great representation across three different sectors of the economy. Like Canada, it's a mixed economy. We've got some mining expertise. We've got some technology expertise and some real estate expertise. I'm going to call upon David to speak first. We've provided some materials that David's provided with respect to I•RES and if you want to take a copy when you go we're happy to provide it to you. Then we're going to call upon Christian to provide an overview of Adventus and its opportunities. Then we'll have Jay speak for a few minutes on that. Then we'll go to questions. All right? Thanks David.

David E: Thank you. The genesis of I•RES goes back to 2014 when Canadian Apartment Properties Reit, which is Canada's largest multi-res Reit, and has always owned apartments only in Canada. I decided that they should look internationally at some other opportunities. One of the early places that they looked at was Ireland. Now, why? First of all it is English speaking which is a major advantage for doing business, particularly in the apartment sector where there's a lot of communication between staff and apartment tenants. Secondly, there had been this crash such that there were assets to buy from a government agency that had been formed to take over the bad loans and assets from the banks when the banks were bailed out. Ireland is a country, historically, of owners not renters. The only rental market of any significance was but to let unit. Like a dentist might own three units, a doctor might own two units but the cab driver will own 10 units though they did not provide professional management services. To try to buy two units here and two apartments there and so forth would have taken forever. It was a one chance opportunity because these assets went into a government related agency called "NAMA". It gave an opportunity for CAP Reit to grow the portfolio. The question then became how do we, without employing a disproportionate amount of our own capital into this, expand this? We watched the new Reit legislation come in in Ireland. Watched two others go public and we're now the largest non-governmental landlord in Ireland. In only three years we have about a billion dollars Canadian of apartment assets and some related commercial space. We're listed on the Irish Stock Exchange. It's been a very successful effort for us and we are continuing to grow. I'll say more about that later.

Ian: Thanks David. That's great. That's great. I'm going to turn it now over to Christian. Christian, I've got some slides here. You tell me when to go forward.

Christian: Thank you Ian. As you mentioned Adventus went public last month. We were the first mining IPO on the TSX in several years. What Adventus is trying to do is create a global zinc exploration and development company. The private team started working in Ireland about five years ago. If you think about zinc and where you want to start a major zinc company, you think about Ireland. Ireland has the highest zinc concentration in the ground at any spot in the planet and it currently hosts Europe's largest zinc mine owned by Bolidean. That mine generates somewhere between a billion to a billion and a half of revenue each year and has recently made a major discovery. I think the mining industry has been a major part of Ireland for many years. It will be a major part many years going forward. Over the last five to six years we assembled the second largest exploration licence position in Ireland. And we also have a significant licence position in Newfoundland which has many Irish ties as well. We've used these properties as a basis to go public but we've got high aspirations in terms of growing this company globally. I've put together a strategic shareholder base that is backing us with several hundred million dollars. Two private equity groups; a large royalty company that's based out of Newfoundland, Canada, and a Canadian billionaire. We're looking at opportunities worldwide to acquire zinc exploration development assets. We'd love to grow in Ireland. We have our sights set on several opportunities and we're spending millions of dollars in exploration currently in Ireland.

Ian: For a former investment banker you're very efficient with the presentation. So there you go. So Jay, over to you. The gauntlet has been thrown down.

Jay: It has. I was going to compliment the Minister on his practice in speaking to Canadians. I understood every single word. I have an office in Cork and we have to have subtitles when we do conference calls. It's technology so as different as property and mining, and it's actually kind of an interesting representation of Canada, we are right at a high tech sector. This is our elephant in the room. Every firm will be hacked and why we had to go to Ireland to get some help. There's a long history in Ireland, probably 20 plus years in Cork specifically, where McAfee, you may have heard of the antivirus company, set up shop. Originally, I think, induced through an R&D tax set up. Then another cyber security firm. Then another one. There's probably 20 to 25 there. The biggest challenge in the industry is access to talent. Fast forward from 20 odd years ago we have educational institutions now training the type of staff these firms want to hire, and if you start looking for concentration, there's some 3,500 to 4,000 cyber security skills right in the Cork area. We had a requirement, this is fairly recent, we brought an investment round in in 2014, and one of the missions was to create a redundant, highly resilient security operation centre somewhere other than Canada. In the US with the Patriot Act, which has changed to Freedom Act, but there was a high degree of apprehension having workloads managed by folks in that country. I would basically wipe out any European or Canadian sales opportunity if workloads were going to the US. It was all around data privacy. However, Ireland being in the EU gave us that advantage. We looked at a couple of other locations. The Hague which has Europol and NATO Cyber Command and then the greater London area. We had three teams go to separate locations. I went to the Hague and the other couple of teams, one of them went to Cork. That's how we ended up in Cork. I'll give you a little bit more colour on the business. We actually sell to mid-size firms and it's managing cyber security risk at the very front lines of protecting the networks. Our customers are assets managers, private equity firms, investment bankers, hedge funds and we've grown this little Canadian company to secure, it's actually closer to three and half trillion of Wall Street assets, and we are on the front lines. We pinch ourselves every once in a while and also break out into cold sweats though knowing what kind of responsibilities we have. But having that obligation to protect, we've got relationships with US regulators or law enforcements, because it's now deemed to be critical infrastructure as it should be. In picking a location we have to be able to have the staff that can deliver the service at the level, we're growing rapidly and every time we're at a customer's, having to add more people. The heart of business is people. Our assets pull out of the parking lot at six or seven o'clock every night and we can't do what we do without the people. For us, our attractiveness to the area was driven by the people. The other locations had the people as well. Then you look for other elements. Like the legal environment, the ability to work with the educational system to get the next generation, we like to use the term different gene pool or DNA pool, to make sure that we have the diversity. You need to have a very tech well supported environment, and the telecom industry hasn't been mentioned yet, but the amount of services that we require are at the upper limit so we've managed to create primary and back up data centres in Ireland that mirror what we've got in Canada. You have to have access to all of these things. We set up in Cork. There's a tech park that was a converted military barracks. We have the officer's barracks. It's all been refitted into a nice modern office space. We had to sort of reinforce the Minister's comments. We had Minister Sean Sherlock at the opening and that, of course, attracted a lot of visibility and that helped. From a standing start went from nothing to a two and half million dollar investment and fully operating full operations centre in nine months which was three months ahead of plan. That's very fast. We brought the team from Cork over to Canada. Did some immersion training in the summer and they were hitting the ground running. That worked out very well. We've hired from the Ministry of Defense and one of the officers we had hired, when he was an officer in the military, this was his barracks. It was kind of interesting close circle. I'll pause there and then answer some more of the questions that we've got laid out.

Ian: All right. Terrific. I've got a few questions here. We've talked about some of these things already. We've touched on this a little bit already but, you know, you've got home base in Canada and this is your roots. You've talked about this. Can you compare doing business in Ireland? The Minister talked about some, frankly, great stats of the Irish economy, but how does it compare to here in Canada, in your experience working here?

Jay: So in the tech world it's hiring and recruiting people and as a business operator you got to manage gross margins. Give you an extreme case. Our gross margins would be half if I staffed up this group in Washington or San Francisco. We wanted to have something that was somewhat on parody with our local rates here. Which aren't the cheapest in Canada but we're certainly not at the San Francisco rates. It's almost identical, in fact, with Ireland, with Cork. It might be different in Dublin but Cork, for us, is almost identical. It's also a captive area that if people generally don't come there, move there, it's a two and half hour train ride from Dublin. They're not going to move there move and move back. So, we've got people in a captive environment. I think it was surprisingly easier for us. The amount of development assistance we got in Canada wasn't very much. It wasn't organized. We worked with the idea extensively. They were the easy button. When you have to find a location they had everything laid out. All the things we had to contemplate. Like, where do we rent? Where do we get a building? Who can furnish it? Which telco suppliers? Here's the people you need to meet at the Universities. It was so well organized. You can tell they have done this for at least 20 years. Compared to the Hague or the greater London area. It was a degree of maturity. I would think we in Canada could do the same job trying to attract. Those were a couple of things on the inbound but the legal environment is very similar to here. So all of that, the payroll and benefits, that was very easy for us to get going.

Ian: So some stuff we can certainly learn from our colleagues and friends over in Ireland.

Jay: Yup.

Ian: David. Can you reflect upon that a little bit?

David E: Yeah. I think Canada has a lot to learn from Ireland. Not just as Jay referenced having a Minister there to open a building and so forth, but we've been there for three years. Minister Coveney since he's been elected, we've not only have access to him, to the Minister of Finance if we wanted, and have had but we actually have a dialogue going. There are some real challenges facing Ireland. There is a real shortage in accommodation that's almost unimaginable. Both in housing, social housing, as well as apartments and single family homes. What happened in 2008 when things fall off the cliff they just didn't develop anything anymore. That's good for us in our business. We also think Brexit will, and already has, attracted new potential tenants for us. But in terms of an ongoing basis, the Minister has brought in some new regulations which have made development there easier and faster, although it still needs further work as he, himself, admitted. The cost structure there and so forth needs to be improved. I think they can learn more, and I've spoken to the Minister on this more than once, from Canada in terms of building for rent units which has never been part of the Irish experience. In Canada, if Cap Reit, being the largest landlord in the country and the largest in the GTA by far, where even to want to see the Mayor about something can be a protracted process, let alone something nationally. As has been mentioned, regulatory language, it's no different than another jurisdiction in Canada. Cap Reit would go into the Maritimes or Quebec, in particular. But the access to the government and support and interest by the government in foreign investment, in real estate, they recognize that only foreign capital can help solve this terrible problem in housing. They are very, very accessible. That's something, I think. It's not just a welcome wagon gift kind of thing. On an ongoing basis, if you have a problem you have somebody to talk to. That's the biggest different I could think of.

Ian: Thank you. Christian, you've obviously spent lots of time as an investment banker dealing with international jurisdictions all the time, reflecting upon what Jay and David have said, what's your experience with Ireland in the sector you're focused on?

Christian: Just like Canada, mining is the pillar of the Irish economy. They've been mining for centuries, primarily in zinc. The Navan Mine that I mentioned has been operating since the 60's and will probably be operating for several more decades. It's a real strong knowledge base of mining in Ireland. Very strong geologist miners. That skill set can be transferred worldwide. There are many Irish miners and geologists work in Canada and vice versa. There's a real great cultural fit between the two countries. Ireland is a neutral country. To give you a sense of the excitement currently in mining in Ireland, because of the strength in the zinc price, Toronto just hosted the world's largest mining conference. It happens each year. It's called PDAC. I participated in a bunch of the events. On the technical session day, late afternoon, it was standing room only and on the Tuesday night at the pub, it was also standing room only. There was a line up right out the door. There was about 20 or so major companies, international companies, work in Ireland. Many of them Canadian and there's just a long history of working together.

Ian: Thank you. I'd like to spend a couple of minutes. We don't have a lot more time, unfortunately, and I'd like to spend a lot of time but I do want to touch on the topic of CETA. You reflect upon what you heard from the Minister, how do you see trade involving Ireland and Canada into the EU? Do you see opportunities to take advantage of CETA and expand both, in Ireland, and beyond in the EU countries? How do you reflect upon that? I'm going to start with Christian and I'll let the other two gentlemen respond as well.

Christian: When it comes to mining I'm not sure that CETA is going to be a huge benefit. Mining's definitely a global industry and you go where the mines are. I'd say in terms of the EU, the biggest draw ever, in particular zinc mining and zinc of course a big part of the Irish economy, is it's probably the most important metal in our top three important metals in Europe. As the use of zinc is primarily for galvanizing steel for vehicle production. It's very close to potentially being a strategic metal within the EU. As a strategic metal there's a significant further tax breaks, incentives, etcetera, that could come out of that. That could help Ireland in quite a big way. Also, when it comes to mining within Ireland, we're supporting the rural sectors of the country which is somewhat different than my counterparts here. The Irish government is definitely promoting that investment in the rural sector. Some of the areas are quite depressed. There's opportunities for grants for companies like ourselves as well.

Ian: Thank you. Jay, what're your thoughts?

Jay: Somewhat similar. We already had all these decisions done and implemented before CETA looked like it was going to be ratified. I think the elevated visibility will be helpful on the trade. We're in the EU. One of the challenges many of you may know in Canada is bringing foreign workers in. Until very recently it was like a 15 to 18 month speed bump. We've got a candidate that we want to get out of Hungary or something and I can't get them here. There's been a bunch of lobbying being done and now we have a temporary foreign visa, expedited process, it's imminent. Be two weeks. Like nothing else in the world. It's kind of in big contrast to the US. We have, as I said, talent and the specific kinds of talent are what we wanted to access. By being in the EU we had that free flow of talent. That to us, I think, the visibility of CETA will probably boost the fact that we're here. I had mentioned the privacy legislation and privacy by design is the model that the EU has implemented. It was developed by our Privacy Commissioner of Ontario, former Privacy Commissioner, Ann Cavoukian. That's how tight the legislation. The subsequent years will be interesting because there's a new law called GDPR, General Data Protection law, in the EU which has security reporting obligations that are like nothing we've seen in the world. Anybody doing business, even if you're not incorporated, will have this challenge. How that gets bound in with the Canadian less onerous regime will be quite interesting in CETA. I've not heard any dialogue on that. Every time it gets into the media is great for us and it just elevates the visibility.

Ian: For every opportunity there's also a challenge.

Jay: Yeah. Exactly.

David: For us, it's more indirect. The more trade between Canada and Ireland to replace what may be lost with the UK, particularly in the interim, is obviously good for the economy there. We're not as dependent on that as other sectors. If it slowed down a bit it would not be a huge problem for us. I think that all these companies that are looking to come to Ireland you all need residences for your employees. So, the extent that those ties come together. We're 99% full so we've never had a block of apartments to offer to foreign companies coming in. We're now in the process of getting planning permission for roughly 450 apartments. We have others well in the pipeline and so we're trying to be part of the solution to the housing problem in Ireland. But we're also directly in touch with foreign companies that are looking to move people or have moved and are in somewhat unacceptable housing.

Ian: Thank you. Thank you very much. I just wanted to say thank you to our panelists, Christian and Jay and David for taking the time out of your day and sharing some thoughts and experiences you've had. I think it's really been insightful. Thank you so much.

David: Yes, we've got a panel of experts here today. I'll introduce them, from your right to left. First, Emmanuel Dowdall is the Executive President of North America for the IDA Ireland, which is the Irish State Agency which is responsible for attracting inwards investment, and probably the most successful such agency in the world, founded 68 years ago. Probably a model for similar such agencies around the world. Don McCutchan, former senior official at the Canadian Department of Finance and a senior policy advisor at Gowling WLG. In his previous roles Don was involved in virtually all areas of government policy and actively involved in the negotiation of the Canada/US Free Trade Agreement. Jamie Fitzmaurice, to his right, his partner, my partner in Mason Hayes Curran's real estate team and Jamie has an international facing commercial real estate practice with particular specialization in portfolio acquisitions for private equity buyers and Reits, including for I•RES. Paul Carenza is a partner in Gowling WLG's Toronto office and a member of its firm wide tax group. Paul advises domestic and international clients on tax acquisitions, structuring and reorganizations and I really appreciate that Paul, today, is taking up a difficult role as the only tax advisor on the panel. He'll be facing some questions, I'm sure, on Irish tax which is a little unfair but it's a reflection of his international expertise that he's agreed to answer some of them. I believe he's up to it.

What we want to talk about today is specifically the ways in which Ireland may provide a good gateway, or jumping off point, for Canadian companies into the world's largest economy with five hundred million potential consumers. I think I want to start with some questions on tax because some of the previous comments, some of the questions that have already been asked have hinted at the Irish tax story. Which is a key but not the only part of its attractiveness to business. Paul, can you summarize for us what the basic tax advantage of using Ireland as a business hub are?

Paul: Sure. Good morning. But before I answer the question, David, I'd like to thank you for your efforts and those of your partner, John Gulliver, in bringing me up to speed, giving me a crash course on Irish tax. Unfortunately neither of them were capable of bestowing upon me that accent. Despite any substance that I deliver today I clearly will not be able to do it in that delightfully lyrical Irish way. So, yes, the Minister made a couple of references. Other speakers have made references to the competitive corporate tax environment in Ireland. It all starts with a 12.5% percent rate. While some of you may have heard of other jurisdictions where there's virtually zero tax, keep in mind 12.5% is comparable to a Canadian rate of 27%, the US rate in the high 30%. Halving what we have in Canada, and more, but that's wrapped up in the context of a tax regime that is EU and OECD compliant. Also wrapped in a regime that has 72 tax treaties with other countries. We're talking about a fairly low rate tax jurisdiction but that is not one that is in the crosshairs of every international organization that is trying to shut down "tax havens" or otherwise shut down what's perceived as improper tax arbitrage between jurisdictions.

David: Drilling down into that, what's the sweet spot for a Canadian company or group that may be considering using Ireland as a hub?

Paul: Three points that I'd like to make. One is the use of Ireland as a hub for a North American business to service its non-North American clients. In particular Europe, Middle East and Asia. The proverbial EMEA hub. Setting up the Irish resident company that, as I mentioned is, subject to a 12.5% corporate rate. Depending on the business that's often capable of providing the sales or licencing into those EMEA countries without actually creating a permanent establishment in those other countries. With the result that there is no taxation in those other countries and the entire profit is taxed in Ireland at 12.5%. In some cases a local establishment in those EMEA countries is required. Those arrangements are often structured in as a limited recourse distributorship or a contract manufacturer so trapping somewhere, say 5-6% of the profit, to be taxed in that other country with the balance, again, subject to Ireland's 12.5% rate. Coming up the ownership chain back to Canada, properly structured, there should be no additional Canadian tax when that income is earned or when it is repatriated by way of dividend to Canada. So a fairly attractive benefit to using Ireland. Another point is the IP regime that is in Ireland. An Irish resident entity can go out and purchase IP and there's a fairly generous amortization or tax deduction regime that goes along with that. The profits that are generated from that IP start off with the 12.5% rate but, in fact, once you have the tax deduction for the write down of the IP you can often wind up with an effective tax rate closer to 6% rather than the 12%.

David: And there's a Knowledge Box.

Paul: The Knowledge Development Box, some jurisdictions call it a Patent Box, this is broader than just patents. My understanding is, and I needed to throw this in because I just like the term, but my understanding is that this was adopted in response to the shutting down of the double Irish sandwich structures that some of you may have heard about. Sounds very exotic but essentially they played on mismatches between characterizations and rules in different jurisdictions to result in essentially lower or no tax payable. The Knowledge Development Box lowers the corporate rate from 12.5% to 6.25% on income that's eligible for that. It does require, however, that the R&D work is performed in Ireland. I think the Minister and others have commented on this that Ireland has a very competitive regime. Part and parcel of their competitive corporate tax regime is to incent economic activity and jobs in Ireland. Which makes a great deal of sense. You lower the corporate rate, you provide great paying jobs and economic activity, you're also creating the personal tax revenue base in your country. The last comment on the Knowledge Development Box is apart from that cut in the rate, that half cut, there's also a 25% tax credit for R&D work performed in Ireland. You couple those together and, again, you have an effective tax rate that is extremely competitive.

David: Just before we leave the topic I think we'd have to mention that there are international pressures on the Irish tax story.

Paul: Yup. Absolutely. And, again, I think the Minister referenced some directly and indirectly. For one, for those of you working with multi-nationals you'll be familiar to some extent with Canada's foreign affiliate regime. Ireland does not have a foreign affiliate or a controlled foreign corp regime. I believe it's the EU that mandated that Ireland adopt such a regime by the end of 2018. I understand that's still a work in progress. One of the consequences of adopting that regime will likely be an incentive, if you will, to on shore back to Ireland, certain passive activities that happen presently in jurisdictions outside of Ireland. Again, from the Irish perspective a good thing. Anytime you're bringing personnel asset activities back to Ireland you're creating the economic activity but you're fighting hard to maintain that extremely competitive 12.5% rate. While some of those activities may now be in low or no tax jurisdictions, bring it back to Ireland, on shore to Ireland, derive that tax certainty where you're not on the crosshairs of every authority across the world and still benefit from that very competitive regime.

David: Yes. Now I want to bring Emmanuel in on the other attractive features of Ireland.

Emmanuel: Thanks very much David. It is a great opportunity for Ireland to be here in the room. I'll do the Irish accent first and Jamie can do it later. I can't get that "about" right but I'll do my best. I think if we step back from it, rather than thinking about it in the context of just bullet points, my experience in this comes down to saying that what companies want to do and what decision makers want to do is mitigate risk as much as they possibly can and make the right choice so that they can develop that sustainable competitive advantage on their own behalf and on behalf of their investors, and their stakeholder group, which includes their customers. The transparency of the environment, the ease with which you will move into that environment and leverage what's there, because of the recognition by Ireland around the importance. 80% of our GDP comes from exports. When you look at the fact that one in three export related jobs comes from foreign direct investment, there's a government focus around making sure that Ireland has the right infrastructure in place. When you have IBM location, IMD, Forbes ranking us depending on whether you are talking about the OCED, the eurozone, or indeed the rest of the world, in the top five ranking from first place in the eurozone to number four on a global basis in the context of Ireland being the right place, or a place where it's easier or easiest, to do business. I think that speaks volumes. You start to look at the common factors that draw into that decision and the most important within that context is, undoubtedly, the access to talent. If you can't get the folks, you can't provide the service. Ireland's attitude to it, when you look at the fact that 15% of our labour force is now international, so you have major brands from around the world providing customer care, platform development, tech support, direct customer engagement on a first culture first language across a multi series of tasks right across the entire internal value chain. In anything from 40 to 60 languages. There's a huge message in that. The message is that people are comfortable to come and live and work in Ireland which makes it a great place to go and source and the skill sets that you're looking for.

David: That's the point that Jay made. It's a pretty easy place to attract people to work, to attract talent.

Emmanuel: It is and there's a lot of discretion globally, for all sorts of reasons, our near neighbours talking about immigration restrictions. There was a recent poll that took, from among Ireland, that said in excess of 80% of people in Ireland were very comfortable with the direction that the Irish economy was going and the makeup of the Irish workforce and the immigration. We're talking about it being an open environment and a welcoming environment. There's nothing new to people who know Ireland. But people who are trying to make a decision on a choice of location it could be something that would be there in the back of your mind. What's interesting at the back of that is to recognize that the Irish government put in place a framework where inter-company transfers, the equivalent of green card processes, can be accelerated and delivered for people who are outside of the European Union. We're an open border as far as the EU 2028 are concerned. But in the context of the rest of the world you're looking at four to six weeks based on what your language requirement. Remember I mentioned 40 to 60 languages. There are only 28 and God knows how many languages within the European Union are spoken but when you walk the streets of Dublin or Cork, the Minister's gone so I can say that anyway, you'll hear languages and accents that go way beyond the borders of the island of Ireland. And being spoken fluently. Some of the companies that are down there and providing that first language capability. One that's borne out by the statistics. When you look at the educational profile. Over half of the 24 to 35 age group, which is right in the middle of where'd we be looking to get that skill set, complete third level education and that's at least 10% points ahead of the European average. The third point, the first one being ease of doing business, talent availability and the third point in terms of access to your market. The reason we're doing this folks is to provide a platform for you to access and grow your market and to access your customers and be competitive. Ireland is a member of the European Union and we're not changing that. We're a committed long term member of the European Union. Been in there since 72 and we've been a founding member of the eurozone. We have a program called the "Excessive Deficit Program" which is another phrase for being bankrupt. When we had that experience, along with the rest of the world, Ireland put in place a program which took us from 2011 where Moody's rated us as junk bonds and 11% government debt. Today, Moody's has expressed absolute confidence in Ireland in the context of a post-Brexit environment. That's basically down to the infrastructure and planning that's been put in place by the government. And as you heard from the Minister and others our government bond trades at just 1%. There's a huge endorsement there and that's on the back of the type of planning. We don't do things by accident. We plan our way through it and, of course, we're all in unchartered water so we're kind of planning for the first time this process. That's not unusual.

David: At that point I think we'll turn towards the future and speculate a little bit about what Brexit might mean, what CETA may bring. But Jamie, let's discuss Brexit. Can you explain why people are talking about these large complex financial institutions, like Credit Suisse, considering relocating at least some of their operations from the city of London to Dublin?

Jamie: Sure. The main reason is passporting, or what's known as passporting, which has become a very key and topical word. It comes up every day in the press. At its simplest it's the ability of a financial service that's providing certain regulated activities under the EU single market directives. If it's authorized in a member state, and has a licence to carry out those activities in that member state, it is therefore entitled to cross sale into the other 27 countries on the same basis without having to be licenced in each of those states. If you're licenced in Ireland to provide those regulated activities you can, without having to, get separate licences from France, Spain, Italy, to cross sale into those countries on the same basis. The thinking being that post-Brexit, it's clearly some of those financial institutions that are based in the large hub that is London, will be restricted in some way post-Brexit. Exactly how we don't know but unless the UK opts, which is unlikely, to remain in the EU it's going to be restricted somewhat. It's very likely that in some shape or format they would have to move some or all, all are very unlikely, but at least some people to bases within the other 27 to allow them to continue to cross into those countries that the red tape and the cost involved in getting licenced in other countries.

David: Actually, can we bring Don in on this. I don't know if you feel comfortable speculating. Which direction are the Brexit negotiations looking like heading?

Don: I was at a session yesterday and the comment was, "I really hope that the Prime Minister, this would be May, has a plan and knows where this is going but I'm sceptical." It comes down to just simply having the resources. You're taking maybe one of the most complex, because it's both trade and political integration, and you're breaking it apart. A week before the Brexit vote the former Cabinet Secretary in the UK was speaking here in Toronto, Lord O'Donnell, he turned to our Cabinet Secretary and said, "How many trade negotiators do you have?" She shrugged and he said, "Do you have 168, seven of whom have dual citizenship and we're talking to them all because we don't have 1. Because the UK hasn't negotiated any trade arrangement in over 43 years." The few experts they do have are working for the commission. There is simply among the manderate, these are competent good people, they say they simple just do not have the capacity to do what's being asked of them, much less in the time frame that they do have.

David: Yes, speaking personally, I found it very personally disappointing. I worked in British politics to see the kind of voices being sidelined. Lord Heseltine being fired from the government. Kenneth Clarke being sidelined. The kind of people who supported Britain's integration into Europe. And it really gives me no pleasure, viewing from Ireland, that the idea that the UK may prefer not to have substantial access to the single market. The phrase that's going around London at the moment is that no deal is better than a bad deal.

Don: Can I just make one comment on that. These negotiations, once they move, they've got two years. CETA and all these trade arrangements, and I'm not a CETA expert, but they all build on the successes and lessons learned of previous. By definition this is the most advanced and given the number of countries involved, one of the most complex, maybe the WTO could trump that. They've got two years. The CETA arrangement, CETA deal with seven years. Harkening back to Lord O'Donnell again, he said, "There's been one sub-sovereign, that would be Greenland, exiting the EU," he said, "There was one issue that was fish. There was only goodwill and that took four years."

David: Now Jamie, at the same time Brexit, if it's going to be as hard as it currently appears, there will be opportunities that I've tried to indicate.

Jamie: Yes. Absolutely. There will be. At the same time it's a bit of a delicate balancing game for Ireland for the professional advisors involved. As you mentioned, as the Minister mentioned, Ireland was against Brexit and the UK is our closest neighbour, biggest trading partner and shares deep social, political and economic ties. We need to be careful not to be seen jumping up and down at the perceived misfortune of the UK but, yet at the same time, if we're not alive the very real opportunities, in particular the passporting, presents to us we will lose out to other countries in the frame, the likes of Frankfurt, Luxembourg and Paris. For example, just yesterday AIG announced that they were going to Luxembourg. There may other insurance reasons for that. We were speaking to one of the Canadian banks just yesterday, myself and David, who has a large presence in London and their informal view was that, in terms of Paris, unless you actually already had an established operations there for linguistic and labour law reasons, why would you? So hopefully that puts Ireland in a good place. For the reasons Emmanuel mentioned, and the Minister also mentioned, Ireland should be well placed to pick up some of this passporting business in whatever shape it takes. There is estimated to be approximately 300,000 passports or licences emanating out of London into the rest of the other 27 countries. Whereas approximately 25,000 or so going back the other way. Clearly London is a massive financial hub. Not all of those are close to it will need to move but a significant proportion of those will.

David: But can Ireland accept them? I l mean, there's constraints. David Ehrlich

David E: Absolutely.

David: Residential units are 99% less, so, where will people live?

Jamie: David mentioned Credit Suisse moving over a couple of hundred people as part of a trading floor. Other institutions which are openly looking. We have the likes of Morgan Stanley, Barclays and Citibank all expecting to announce where they're going to go, in some shape or format, and the key problems I think Ireland are going to face are infrastructural and David's mentioned some of them. It's where will these people live, where will they work and how will they get to and from work? The Irish property story is well known. We had a spectacular property boom and an equally spectacular bust. The result of which was there was a good 7, 8, 9 years where there was very little investment in residential infrastructure. Even at the moment it's estimated that on the sale side, 1% of the housing stock is actually for sale, whereas for a functioning economy it's estimated to be four. They supply and demand for actual places to live based just on the current demands, it will take 10 years for current rate of construction to meet the demands of the Irish market, let alone any influx that's coming in as a result of Brexit. But the government and Minister Coveney has been alive to this and there is a housing strategy. I know David says it needs a little bit more work but there is a fast track process for large residential units. There's been an investment in the infrastructure to unleash, or unlock rather, development sites in the greater Dublin area and there's been a commitment to doubling the number of units by 2020. NAMA, the former bank which David mentioned has been given charge of providing 20,000 odd social units for housing units which will take away from the constrains in the greater Dublin area. The other main thing is where will they work? The where will they work situation is probably not as bad and we're very well placed in that regard. Clearly everyone, even if you want them all to come, won't come tomorrow. As things are at the moment there are 4.5 million square foot of office space in the greater Dublin area, either being built or being refurbished, with platform planning permission for another five million. So the key from an Irish perspective, an Irish ink perspective, is getting that stuff ready and having it ready to go, if and when, these financial institutions decamp over to Dublin.

David E: There's one point I'd love to just pick up on if I could and it was a comment that Don made. It's an interesting point. When people talk about a two year period once Article 50 is triggered. I listened to our own Ambassador, Ireland's Ambassador to the European Union, Ambassador Kelleher, in January and I can't remember the specifics of the timelines but you must understood that that's a soup to nuts. That's a beginning to end process in terms of the time frame. Within that there's a period for negotiation. There's a period for drafting and then a period for redrafting then a period for renegotiation and then you get to probably year three or four at that stage. In the context of compressing it into a short time frame, especially in the context of how many executives and what sort of intellectual capital is behind it, it does underline the challenge. I think that the uncertainty that that creates in the minds of a decision maker takes you back to where I started and you say, "I want an environment where I know where I stand." But I think the two year period, when you break it down, as any of us who have ever circulated a document to our board, knows that that starts a long time beforehand or else I don't know how you achieve it. I don't know how you achieve it. That's just a small point that I thought.

Don: Two quick comments on the transitioning, either leading up to, or post-Brexit. One is those structures that have a UK company with European subsidiaries underneath it right now benefit from the so called EU parent subsidiary directive which eliminates withholding tax paid from a European subsidiary up to a UK holding company. That obviously will no longer be. So there's apparently a lot of consideration about adding an Irish holding company to that structure and merging the UK holdco out of the UK into the Irish holdco for continued access to, and benefit, from that EU parent sub directive.

David: Yes. That hasn't been a headline issue at all but theoretically companies with EU companies in their group could face a dividend withholding, dividend stock below. And we've been advising on cross border mergers through mergers or fusions of companies into Ireland to remedy that. It's assumed at the moment that the UK, we don't know the final deal, but it's difficult to see how the UK could benefit from the parent sub directive in the future. It's a good point.

Paul: Interested in a passing comment on the people that are going to be potentially moving to Ireland and personal level tax. Ireland has this great very low, very competitive, corporate tax rate. Their personal tax rates are comparable to what we experience in Canada. I think, in fact, their highest marginal rate may be a point and a half less than what we enjoy in Ontario.

David: What's some of the thresholds start at?

Paul: The thresholds start significantly lower than our thresholds. So, we maybe do enjoy something in Ontario. I don't know.

David: There's a bit of planning to be done.

Paul: That's just it. When you're sending someone over they're looking at their personal tax rate, they're looking at the VAT which is about double ours, here. The VAT's in the mid-20's. The cost of living. I understand there is nothing in Ireland comparable to our stock option regime which is a key component of the compensation I suspect of many of you. All to say a lot of thought and planning needs to go into that piece before the person gets on an airplane.

Don: The trade between Ireland and Canada is fairly modest. But it will know next week, on the 15, whether the populace irritation or angst is an Anglo-sphere issue. It seems like the Dutch are moving back away from following Trump-ism and Brexit. But there is no doubt that in Ireland's principal trading partner, and our principal trading partner, the border is thickening. How long that goes on for, who knows, but it is a reality. What we can do in addition to the business that now exists is provide platforms. Ireland to the EU and as everybody's touched on the, in Canada's case with the exception possibly of the United States, the similarities between parliamentary systems and cultural affinities would be closest to Ireland of any of our trading arrangement. It is incumbent on both countries and their policy makers to diversify trade. That does take time. But I think we've heard from here that whether it's financial services, which is without doubt the only, mining and financial services are Canada's world competitive industries, but it was touched on pharmaceuticals, high tech, Toronto-Waterloo corridor, the second only to Silicon Valley. Even though starting off the opportunities for working collaboratively, start from a modest base. I think there is considerable potential given the political unrest in our two major trading partners.

David: Yes. And the counterpart to our session here is a session that both Jamie and I attended in Dublin using Canada as a gateway to North American markets as a low cost access point and CETA with the removal of tariffs, removal of non-tariff barriers. Mutual recognition of qualifications which may be a very important part in the accessibility to diversify into North American markets. Sending professionals in one direction and the other. That's an important part of the background and maybe our future.

Thank you very much. We're just at our time now so I would like to thank my panel, Emmanuel Dowdall, Don McCutchan, Jamie Fitzmaurice and Paul Carenza. Thank you very much as well for attending.