Maya Forstater

Essentially you are carrying out a shadow unitary tax calculation, and then being surprised that it doesn’t reflect the actual tax paid under existing tax systems.

Thanks Maya. That's a mistake in the graphic, will sort it.

Fixed, thanks. On your point, Dan, it would be interesting to hear your thoughts on the overall argument, which might explain the element you don't follow (or don't like?) here?

Unless I am misunderstanding, your approach is to compare the tax that is actually paid with the tax that would be paid if taxable profit were aligned with “real economic activity”. 1/3

You then define the difference as profit shifting. But “real economic activity” is not how existing tax systems work. You’re not measuring profit shifting at all.

As the entire purpose of the BEPS project was to change the law, is it not a pointless exercise to only define BEPS in terms of how the law currently operates? Such an approach would entirely defeat the purpose of the BEPS project wouldn't it?

Of course I accept some of the alignment is down to intentional BEPS. But you cannot assume it all is, when that is just not how current frameworks work.