Maya Forstater

Govt of India is UK case. Buchanan v McVeigh is Irish one. Very tricky if parent says no.

I'd venture a guess and say any practical solution, to be successful, would have to rely on innovative 'diplomacy' or geopolitical might (see e.g. TheTaxThatShallNotBeNamed) rather than strictly legal procedure

Yup. How do countries have legal jurisdiction to require local filing of Master File, but not of CbCR ? (since they are both data held by ultimate parent)? @AlexParkerDC @martinhearson

Perhaps because I am a lawyer, I don't understand the issue other than Aisling's last tweet. Vietnam says 'we don't care about the corporate veil, just give us the info or face X consequence', company makes its choice.

But, consequences can only be for Sub Ltd and if Parent Ltd is secretive e.g. owned by an oligarch Sub Ltd can't control lack of data. It's bad law in the respect, penalizing a party for matters beyond their control.

I get the secrecy issue, but I just don't see the issue with penalising a sub for parent's non-compliance, since they are under common control.

Depends on level of penalties. What if they put Sub Ltd into financial difficulties costing jobs? What if they render local directors of Sub Ltd criminal? They'd need to be that kind of level to force extra territorial compliance.

Yeah I wouldn't put it past Vietnam