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Thanks. So your answer is in short (rudely paraphrased) «yes it could be, depending on the interpretation of the concept of IFF»?
Sort of. I guess the question is what for. Yes understand behaviours & measure financial impacts. But does the category 'IFF' make sense -- i.e. does it make sense to lump *this* in with money laundering, bribe paying, theft of public assets ?
That is a political question, not a methodolgical one in my view - the result is the same, the motivation is similar, though the source/incentives are different. My political call is - yes it makes sense. At least more sense than not lumping it.
Yes its political, & depends what u trying to do. If it is something that is legal but you want to stop it (like thin cap where there are no thin cap rules) then need to include ppl using current rules in consultation etc which u can't do if u call them illicit & lump w criminals
Practically i think the test is - if you hold a meeting on IFFs who will come? Not the people who really know about the legal, practical and commercial aspects of avoiding BEPS thru dividends & interest. And if they did come they wouldn't have much to say to the AML folks.
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