Maya Forstater

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.

It’s a category error - the misalignment calculations don’t and can’t measure tax avoidance or evasion. They measure the imperfection of the status quo vs an idealised unitary tax system

You say it's a category error Dan, when it is explicitly identified on the approach that misalignment > shifting.

No, the IMF methodology is about BEPS rather than misalignment. (Our BEA study is misalignment.)

To repeat: “Lawfully achieved misalignment”= intentional tax avoidance. In reality misalignment = “natural misalignment” + evasion + avoidance. Where does your piece acknowledge that the first category exists?