Subcommittee on Tax Matters Ordinary meeting EU Tax Symposium 2026
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FISC European Parliament
Speaker 2
He's also chair of the UECD Committee on Fiscal Affairs and co-chair of the Inclusive Framework, the forum in which both pillar two and eventually the side-by-side agreements were developed. So let's start with theme, actually, because team was really involved with a pivotal role in the negotiation process that led to the first BEPS agreement, and then to the side by side. And I would like, Tim, if you can, to explain how this side-by-side agreement came through, what are its main features, and of course, what is your assessment of this compromise that was found to bring the US back to within the BEPS agreement?
Speaker 3
Well, thank you Francesca. I mean, the side by side agreement has a number of components. It introduces simplifications to the rules that I think Ranluca will talk about later. It makes changes to the treatment of tax incentives under the pillar two rules, which I'll come on to talk about later. But it also, perhaps most importantly, addresses how US multinational groups should be treated under the pillar two framework, and this applies some of the pillar two rules to US multinational groups on account of the separate US minimum tax rules that apply to those groups.
I think the agreement was a very substantial achievement, particularly given the sensitivity of the subject and the speed at which it had to be reached. I think it wasn't the outcome that the UK and many other jurisdictions would have ideally chosen. You know, pillar two was predicated on the idea that the same standard should apply to all multinational groups irrespective of where they're parented, and the side-by-side agreement clearly departs from that and raises some questions from a competitiveness and level playing field standpoint. But at the same time, I think there were three things that really drove jurisdictions towards compromise. I think there was, first, an unwillingness for this to be a major source of tension in an already very crowded geopolitical environment.
I think, secondly, a big concern about potential threats of retaliation of the type that have been proposed by Congress under section 899. And then third, but perhaps most importantly, I think there was significance that countries saw to the US administration trying to reach a negotiated multilateral solution on this issue, and a view that coming to a negotiated multilateral solution rather than having reactive bilateral solutions would best help to uphold and preserve the Pillar two system more widely, but also maintain the right conditions for international cooperation on tax on issues like digital taxation. So I think it was a political and pragmatic compromise, but I think it's important to look at its evaluation and assessment, taking into consideration what might have happened had we not reached that agreement. There are kind of four points of detail that I would just bring out that I think helped countries like The UK, but also EU member states, to reach this agreement even if they were looking at this through a very pragmatic lens. I think the first is the point that Matthias raised in his keynote speech, which is that this isn't an exemption for US multinational groups.
Speaker 4
It disapplies the rules for US multinational groups on account of the existing US minimum tax rules that apply to their domestic and foreign profit. And those rules are different from pillar two, and we might come on to some of those differences, but they are meaningful rules. They have the same overarching policy objective, and their existence predates Billeteau, and I think all of those things are important. I think, secondly, the agreement preserves the right of jurisdictions to tax the local profits of US groups. If, for example, a US group is subject to low taxation in Hong Kong, the UK can no longer apply top-up tax to that profit.
But if Hong Kong chooses to do so, it can. And if a US group has low tax profit in the UK, the UK is entitled to tax that. And I think that's important. It's important in preserving sovereignty of jurisdictions to tax local activity, but also, I think, in preserving the policy aims of pillar two, because many jurisdictions have introduced domestic top-up taxes since the rules came in, even some quite tax-favored jurisdictions traditionally. And then the final two points.
I mean, the third point is that the agreement doesn't close the door to other jurisdictions accessing similar treatment, but the door is only very slightly ajar and very heavily guarded, I would say. And that was a deliberate choice, and I think it's important in trying to preserve the common approach in the policy and administrative benefits that come from that, and avoiding there being a big patchwork of different domestic rules in different countries. And then the fourth and final point, but a very important one, is that the agreement crucially includes a commitment to review the rules and undertake a stocktake in 2029, and a commitment to take action if there are issues that emerge from the perspective of the level playing field or from a BEP standpoint. And I think that is a really important commitment and one that means that some of the concerns that have been quite legitimately raised can be evaluated again and evaluated with empirical data and evidence to support that as well.
Speaker 2
Disappointing because it's double standards, but the double standards. They're not really double standards. And b, it was a price worth paying to avoid adding to the international tensions that we're living in right now. Well, the same question now goes to the other two members of the panel. What do you make of this assessment?
Let's start with Zorka.
Speaker 6
Thank you. So I wanna start just by saying that I support pillar two, and perhaps you don't hear that very often from a US perspective, but that is one of the things that I wanna frame, that there is still significant constituency in The US that, you know, believe that, you know, pillar two is in The US interest. And overall, I think Tim already kind of summarized it, and I largely agree. I think that pillar two was necessary, but regrettable. And one of the, I just wanna list a few reasons that from my perspective, it was regrettable, but also some positives.
Speaker 5
And, you know, to start with, I think it is unfortunate to have double standards. It's especially unfortunate because the US is weaker in some respects than pillar two. I don't want to go into the details. We don't have time for that. Some of that evidence has already been shared with members of the parliament by US expert professor Clausing.
And it's true that other countries can apply for the same treatment, but there is nonetheless this double standard because we know that this was done kind of under considerable pressure from the Trump administration, you know, threatening punitive retaliatory taxes that were, in my view, frankly ludicrous and would have hurt the US economy perhaps most of all. And so in my view, I think that the section 89 really never really stood much of a chance of passing congress anyway. So I think that was all very unfortunate. It's also regrettable in terms of, you know, transparency and legitimacy. I mean, it's just not a great look that this was kind of done in secret, behind closed doors.
I understand that it had to be done that way given the sensitivities, but it wasn't evidence based, and, you know, that's just not ideal. And I have to say, also from where I sit, I'm surprised. I'm stunned, frankly, that the US was able to convince other governments that it taxes its companies robustly. I mean, we know that it was the tax practices of major American multinationals like Apple and others that prompted this discussion in the first place. And we know that some of these problems persist to this day because I looked at annual statements of major American companies that have been recently filed, and we still find significant evidence of profit shifting.
So the problems have not gone away by any means. And there are also considerable revenues at stake, so not to go into the details, but I know there are some early figures from the UK, from the Netherlands that kind of show that this will have revenue costs. So that's the glass half empty, but I want to also turn to the glass half full. And, first of all, I wanna commend Tim and other negotiators and the OECD staff who I think navigated this very tricky terrain quite well, and it resulted in an outcome that was overall sensible. I mean, not ideal, but I would say sensible.
So, what is sensible about it? I think the fact that the standard for side by side treatment is, you put it so well that the door is kind of ajar, but slightly and heavily guarded. I think that also kind of helps to preserve the baseline from the US perspective and reduces the risk that the US can go lower, and I think that's important. And second, and maybe I think for me, from my perspective, the most important thing is that there is going to be a stock stake in.
a few.
Speaker 5
years, which is a chance to kind of look at how the rules are or are not working. And I really hope that this stock take will be done in a more transparent and objective way than the way that, how the negotiations, took place. So, yes, in my view, the bottom line, I think the side by side with all of its pros and cons and flaws was not perfect, but hopefully, it can be improved.
Speaker 2
Okay. Two glasses are empty and full. And I note also that you both highlight the importance of having an assessment in the medium term. The floor is yours, and the question is the same.
Speaker 7
Thank you. I guess from my perspective, the biggest problem with what happened last year was that we spent a whole year basically talking about the need for a side-by-side solution when we were in desperate need for, you know, more clarity on how to apply the rules. So in my mind, the fact that we lost all that time was something that should be considered. I do agree that we needed a solution. Right?
And I think it was really important to have it done when it was done, because we were living in this environment of total uncertainty. And I think more than anything, businesses need certainty around how to apply the rules, whether the rules apply to them or not. I also think it's a big win that domestic minimum top-up taxes have survived. So as Tim explained, each jurisdiction that is part of the pillar two framework is free to apply this top-up tax domestically, even though maybe the upper layers of pillar two don't apply. So I think those are two big wins.
When it comes to impact on competitiveness for EU businesses, I think the assessment that was already mentioned and underlined by you as well will be very important. There is probably a clear disadvantage for European businesses investing into the United States because they are not protected by the side-by-side safe harbor, and they will have to deal with both the US GILTI regime, which is not called GILTI anymore, but let's call it that for argument's sake, and the income inclusion rule or UTPR under Pillar two. And I think that's something that will need to be considered when the functioning of the system is assessed. Although some of that is mitigated through the preferential treatment of incentives, that I think Tim is going to talk about. So, pluses and minuses.
But I think one point that is maybe lost in the conversation is that there is a tendency to focus on the competitiveness of the EU when compared to the United States, but we probably need to look at competitiveness compared to other parts of the world. So if we look at Asia, for example, I think we, in Europe, need to ask ourselves whether it's important to assess our competitive position with respect to Asia. And I think the answer is yes. And what pillar two has achieved is it has leveled the playing field when it comes to Europe versus Asia as well, because there are actually significant top-up tax amounts being paid by jurisdictions that are headquartered in Asia. So I think we need to look at this holistically.
As has been said, it's not ideal. In my opinion, we spent way too much time talking about this, but there are some pluses as well.
Speaker 2
Thank you very much, Luca. So I think what I take from your answer is that, first of all, there is a contradiction. Right? Because Trump is trying to attract non-American firms with his tariff policies. And at the same time, the side by side agreement actually will hamper the relocation of EU firms' activity in The United States.
That is quite an interesting remark. The other remark I want to make is that, I mean, it seems that the major problem with the side by side agreement is that it kind of dents a little bit into this principle that was introduced with pillar two, which is that fiscal competition is something we should try to curb. And that was, in my opinion, the main, if you want, implication of pillar two. And this is a little bit weakened. But let's go a little bit into the details, because as Tim said in his very short introduction, there are other provisions in the side-by-side agreement which seem to me more consensual and more important and more positive.
The first is that the tax incentives change a little bit with respect to what they were under pillar two, and then there is a very strong emphasis on simplification of the rule because pillar two was considered to be a little bit cumbersome. And so let me start again with Tim. What can you say about tax incentives? What do you think, where do you think we stand after this modification of the agreement? Yeah.
Speaker 3
I mean, thanks, Francesca. So the side by side agreement changes how tax incentives are dealt with under the pillar two framework. The original agreement said that corporate income tax credits that are refundable to claimants that don't have taxable profit should not be treated as a reduction in corporate income tax for the purposes of pillar two, even if they're actually set against corporate income tax liabilities. And that had a logic. Refundable credits have many of the same properties as government grants and are accounted for on a similar basis as items of income rather than reductions in tax.
But despite that logic, that approach, and the distinction between refundable credits and nonrefundable credits, proved to be very contentious. You know, there was strong opposition in the US to the nonrefundable US R and D credit having less favorable treatment under pillar two than, for example, the refundable R and D credits in the UK and France. There was strong opposition of countries that said that this was favoring more developed and better resource countries who are better able to please some of the fraud risks that come from refundable credits. And there were other jurisdictions that said this was creating some arbitrary differences in how they try to incentivize important economic objectives, whether those relate to infrastructure, the environment, or digitalization. And I think it was clear that to land this side-by-side package, there needed to be a change in this area, one that didn't remove the distinction between refundable credits and nonrefundable credits, but made the effects of that distinction less pronounced.
I think the discussions on what that something was were quite difficult. I mean, once you move away from a discussion on, you know, is a credit objectively similar to a government grant, you end up with quite a subjective debate about what credit should be subject to more or less favorable treatment under pillar two, based on their perceived harm. And you obviously had jurisdictions approaching that from very different standpoints, some wanting very permissive treatment, some wanting very restrictive treatment. But I think we've ended up with a sensible compromise in the package, which basically provides for more generous treatment of nonrefundable credits insofar as those incentives are tied to and support economic activity in a jurisdiction, rather than just facilitating profit shifting. I think some will argue that those modifications weaken the pillar two framework, and some will argue that they lead to some of the circular arrangements that we've seen today with countries raising top-up taps, but then passing those benefits directly back to groups.
Speaker 4
But I think it was an essential component of the agreement, and I think the additional flexibility it provides to jurisdictions might actually increase the likelihood of jurisdictions adopting and retaining the pillar two rules. And kind of back to the point I raised around the side-by-side agreement, I think those incentives for adoption and retention are gonna be the thing that ensures that this is durable and sustainable over time.
Speaker 2
So overall, your assessment is quite positive. It kind of reduced the distortions that were in Pillar 2. What about simplification?
Speaker 7
Well, for those in our audience that haven't seen the package, I would like to just say that the part on simplification in the side-by-side package is close to 60 pages. So I don't know if we can call that a real simplification. I think there's still room for improvement. Of course, joking aside, it was important to have that simplification. It was probably less than what some MNEs were hoping for because it's still based on accounting data, and that is very difficult for MNEs to source.
And I think there was not sufficient understanding in the initial stages of pillar two around how much data MNEs actually have at hand, in particular when it comes to basing that data on local accounting standards. I think we're now in a better position of understanding, you know, the accounting implications and how those financial reporting standards relate to pillar two, and a better understanding of what data is actually available and how much effort and resources M and E has had to put into becoming compliant with pillar two. So there is still room for simplification. In my mind, we have a tension between the need for clarity and the need for stability. So on the one hand, we want to have more guidance on how to interpret some of these provisions.
But on the other hand, we want the system to stabilize. Right? Because, as I said, certainty is probably the most important part of being compliant. Obviously, you know, when it comes to interpretation by local jurisdictions, that it's an added layer. And you would not believe how much time we spend on one word in a particular paragraph in the pillar two rules, or in the commentary.
And we look at how different jurisdictions have translated that word into their legislation. So every single aspect of the pillar two rules creates complexity, and I fear that that's not going to change. I think in an ideal world, I would like to see further simplification through maybe a recast of pillar two. So what the European Commission is trying to achieve with the Director of Administrative Cooperation, sort of bringing all the texts together and looking at how it would be possible to simplify and eliminate overlaps, I think that could be done for pillar two. We have the initial text.
We have so much administrative guidance. We have so many open questions. So why not, at some point, sit down and look at it all again, and see if there is scope for the rules to be rewritten into a cohesive piece of legislation. Because what happens now is that we have administrative guidance that not only clarifies points in the GLOBE rules, but also introduces new rules that sometimes are opposed to maybe what was in the model rules to begin with. So sort of cleaning up the house, I think, would be the better way to achieve simplification in the long term.
Because we're talking about a system that is going to be in place for the foreseeable future, right? So we don't just need transitional rules. We don't need rules that will work in the next 1 or 2 years. We need rules that will work in the long term. And the simplification that was brought in allows the minis to, you know, jump in and out of the safe harbor, which is a complicated way to do things.
So I think in my dream world, we would have substantive simplification through a sort of a recast of the rules. And I think it will be good to look at what can be simplified in terms of other anti-abuse rules on the basis that pillar two is a sufficient framework as a basis for, you know, stopping base erosion and profit shifting. And I think this is what the European Commission will try to do here in the European Union, to see what existing measures can be eliminated on the basis that pillar two is now in place. And ideally, I would like to see that in the international arena. Right?
So for groups that are in scope of pillar two, why not have consensus around eliminating or softening other anti-abuse rules in double tax treaties, for example, or domestic legislation? So in my dream world, those would be the two asks.
Speaker 2
Thank you very much, Luca. So I guess the simplification needs to be a part of the assessment that will happen in a few years. We finish with you before going to the public Zorca. And it's a more general and yet very important question, especially given the current context. How do you see the future of international, I would say, transatlantic tax cooperation?
Speaker 5
Thank you. That's a great question. Look. I'm an optimist, and that's definitely not easy these days. But I'm encouraged that most and hopefully even all of us who work on international tax policy can agree that, you know, international tax cooperation is important.
And, I'm grateful that we still have it, not just at the OECD, but also, you know, the UN is another forum where discussions are taking place, although the US is not a part of those discussions, unfortunately. But at least The US has not withdrawn from the OECD even as it has withdrawn from other bodies and threatened to defend them. So at least we still have the OECD. But on the Transatlantic specifically, side by side, it is what it is. We've already kind of talked about it.
More broadly, I would say, you know, from my perspective, I think it is in the US interest to have a strong Europe, you know, geopolitically in terms of, you know, security and defense and other issues that we're not talking about here. But, also, economically, I think that is in the US interest. And so, you know, it's not for me to say what Europe should do, and I recognize it's very tricky to deal with this whiplash from across the ocean. But Europe is a major market, and it should have more self confidence in tax and trade matters. And if there are competitive imbalances that need to be addressed, I'm sure that the EU has many policy tools to deal with that, you know, be outside of pillar two and the OECD.
You know, maybe, I don't know, there's the foreign subsidies regulation. There are procurement ways to address these things. Be creative and be strong. I think that would be part of my message. And the other thing I wanna bring up, just briefly, I know we don't have much time, just to take a moment to consider the lessons of tariffs, which I'm surprised have not really come up in the conference so far.
And I'm surprised. I mean, tariffs are a trade policy, yes, but they're also a tax, and they're deeply unpopular, not only here, but also in the US. And so, you know, as you probably know, they were recently struck down by the Supreme Court, and I think I don't expect the replacement policy to fare much better in courts, frankly. So I think the takeaway there is that, you know, not everything that the current US administration does or says will necessarily hold up. So maybe, you know, take it with a grain of salt.
Speaker 6
I'm not gonna say call their bluff, but, you know, just yeah. That's one of my messages, that I wanna make sure we also have some time for questions. So.
Speaker 2
Well, this goes a little bit against the emphasis on uncertainty that Luca was mentioning. So we have less than 10 minutes. I have 4 questions. So I will give the floor to the four people who have been selected for the questions, and then we'll have the remaining time for you to answer. So the first is Massimo Garavaglia from the Italian Senate.
And the seat number is 199. I will cut you at one. I don't know where is 199. I will cut every speaker at one minute, sharp. So keep your remarks and the question within one minute. You have the floor.
Speaker 8
Thank you very much. Well, the European Union has got a big competitiveness problem. But what's the solution to that problem? The solution: more tax, more bureaucracy, or is it to reduce tax and bureaucracy? Of course, it's gonna be better to remove them.
There's a lot that the European Union can do on its own. I've got two questions for you. First of all, energy is key to development. China has halved the cost of energy, particularly for its use of AI, whereas the EU is making it more expensive through the ETS. Can't we suspend the ETS system?
Second question, we've got a lot of useless reporting, particularly environmental reporting for small and medium-sized companies. If there's a problem out there, the solution as we see it is cut taxes, cut bureaucracy. Don't add new taxes and bureaucracy.
Speaker 2
Thank you very much for being on time. The second speaker from the Hungarian national assembly, I cannot read the handwriting, is mister Severny 192. I'm sorry if I misspelled your name. You have one minute. Thank you.
Speaker 9
very much for the floor. Hungary, as a member of the EU, is part active part of the OECD framework. We are committed to the BEPS framework. We also support the solution to the digital services tax, and we want to avoid tax evasion and thus create a fair taxing system. And we also support steps against aggressive tax planning, but we also believe that a fairer taxation system shouldn't reduce our competitiveness.
Member states should be able to continue to decide on their taxation systems in a sovereign manner, taking into consideration their level of economic development and other factors. Thank you.
Speaker 2
Thank you very much. The third question will be from Greece, the Hellenic parliament, mister Kukulopoulos, and the seat number is 1110. I didn't miss your name, too.
Speaker 11
Thank you, Chairman. In the second panel, we heard that we do not have time to lose. Now I would like to repeat a proposal made in November. Europe has to move without any hesitation to decide to tax the big, very big companies and the profit where it's produced, pillar one, because that is just. We have allies, the UK and Canada and very many other countries.
Speaker 12
That's what we have to do. We have no time to lose. And noted with interest, we heard a while ago from the USA for Pillar one specifically, they want some cooperation, some discussions. They haven't done that concerning tariffs that were imposed unilaterally, not even the rules of international law were unilaterally, they take actions. So we have to decide and move ahead without hesitation.
Thank you.
Speaker 2
Thank you very much. Everybody is on time. I appreciate that. Last question, and then we have a quick round of comments and answers. It's from Mister Somesh Jia, I think.
I cannot read. Two 3 2. And he's from the Republic.
Speaker 13
I wanted to ask this question to Tim. The one of the major differences between the side by side framework and the US global minimum tax is the blending of tax rates, right? So, is there a chance that the OECD will look at giving the similar treatment to non-U. S. SMEs as well?
Speaker 2
Thank you very much. 64 seconds. I really appreciate it. So I maybe without any, without me giving you the order. Who wants to start replying from?
Speaker 7
I would just make one general comment that I think addresses some of the initial questions that were asked, which is I don't think tax is the answer to everything. Again, there is a temptation to look at fiscal policy or new taxation measures to fix all of the problems that a jurisdiction has or that the European Union has. And I think, although we tax people like to think that we are the center of the universe, I think we need to take a step back and look at what other measures can make a jurisdiction competitive, can make the single market work better. So, of course, tax is a very important tool, and it's very important that European jurisdictions maintain the ability to decide on their tax affairs as they see fit. But I think we need to look beyond that because we have this immense pressure in taxation between the need for harmonization and the rights of each European jurisdiction, which means that we sometimes cannot make the progress that would be needed, and maybe we need to look at other areas of EU law, and not just taxation.
Speaker 3
I think first, I'd say on the aims of Pillar two, I think it is important to remind ourselves of what the aims actually were. I mean, I think we can get a bit lost now because it's so novel and unprecedented, and people are rightly and naturally concerned about the administrative burdens it's creating. But I think it was to place a floor on tax competition that, at the time, was seen as deleterious, and to address multinational profit shifting that was quite significantly eroding trust in tax systems and compromising countries' ability to finance public spending. At the same time, the idea was never to constrain countries from being able to compete, and the rule system has been designed importantly from a UK perspective to still allow that. And I think that was an important part of the side-by-side agreements change to tax incentives, was to get the balance right, I think, between those two things.
I think, you know, on the question that was raised around the difference between the US minimum tax system and pillar two, clearly, the way in which minimum effective tax rates are calculated, you know, one looking at the aggregated foreign operations of a group, one looking at the operations of a group in individual jurisdictions is clearly very different. And the US approach, at least in theory, means a group can realize profits in a low tax jurisdiction without top-up tax if it also has profits in a high tax jurisdiction. That said, there are many other components of the US tax system that are stricter than the Pillar two regime in terms of how effective tax rates are calculated, and, for example, not taking into account some of the quite innocent things that can lead to low effective tax rates that the Pillar two system tries to deal with. So it is really comparing apples and oranges, and we've had to do a very detailed assessment within the inclusive framework of that. I don't think we've convinced everyone that there aren't risks and challenges, but back to the point I raised in my opening remarks, I think there's an opportunity to assess those risks with more empirical data in a few years.
Speaker 5
Yeah. I agree with Tim's points. I think, you know, the blending issue is a difference, but how it nets out with all the other differences is really hard to say, and important to look at that empirically. You know, we are kind of starting to do it just that and look at some of the disclosures that are coming from the companies themselves, and then we will also have more evidence from country by country reports, from Europe, and also, going into effect in Australia. So we will really be able to have a better picture, you know, not just in the OECD negotiating rooms, but also to inform the public debate.
And I think that's important.
Speaker 2
Thank you very much. Sorry to the public and to the speakers for this tight time constraint. We have been good, I think. So I think our speakers deserve a big round of applause.
Speaker 1
Thank you. Thank you so much, Mr. Salacino. You did a wonderful job. You have not been good. You did an excellent job in time management, which is remarkable when being in a parliament setting.
And thank you to all members of the public, members of parliament. You've really kept yourself to one minute. I told my colleague, it's never going to work. They're never going to keep the one-minute time constraint. So thank you all.
I think you also probably knew why, because there's a very important part coming right after this one. We're in Belgium, the European Union, the heart of the building is located in Belgium, after all. So food is a very important part of the day. So lunch is coming. Tim was talking about not comparing apples and oranges.
Well, there's no need for that during lunch. You can have both, I guess. Oranges, apples, whatever you want. So I would like to ask all members of the national parliaments, European Parliament, speakers and moderators to remain seated for a few more minutes because there's a family photo going to be taken. That means that all the rest of you will be served food first.
So you'll get food before they will. So take advantage. You can actually go out. We meet again at 20 to 2 sharp. We start again.
So 01:40 PM, we start again right over here. For lunch, just listen to me for one more minute so you know the way to lunch. People attending last year, it was not the same location. So do not say I remember where it was, because you will not find it. You go out of the hemicycle and you take the stairs two floors down.
Two floors down. The ones on top, that means you have to take the elevator to the 1st floor. People seated here, two floors down by the stairs, will have their lunch served. Back here, seated at twenty to two, for a sharp delay. And if coming back in later on, pick up speaking cards if you want to ask more questions in the afternoon.
Speaker 17
Thank you once more to the wonderful panel. Thank you. So good. So good. Okay.
Speaker 1
Okay. So that means that all the members I've invited for the family and group picture try to gather in this middle part. You can use the first row because we will all be standing. The photographer is going to set up a ladder on stage, so he will be high enough to take a decent picture of all of you. So, yeah, just fill the space in the middle.
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