People who are cited in the article: "British tax barrister Clair Quentin, who developed the concept of Risk Mining", "TJN's Director Alex Cobham", "Jolyon Maugham, a prominent UK tax barrister", Sol Picciotto ... and some nameless person at CGD. Who could that be Nick? 
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The article spends a lot of time on the 'grey' area of tax which is legally due, where audits can enforce compliance. Reasons for audit adjustments can include normal uncertainty, aggressive avoidance & behaviour that might be evasion.
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We are all agreed this tax should be paid. Clear laws, more audit capacity. Stronger enforcement, including penalties for egregious behaviour. All important.
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But I do not think it aids understanding to bundle all of the revenue at stake in CIT audits with "illicit financial flows" - i.e. with money laundering, fraud, corruption, theft of public assets, organised crime. Different stuff. Different remedies. (also not really a 'flow').
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What Nick fails to mention is the *further* category that he & colleagues at TJN are proposing to be included in measures of "illicit financial flows" -- that is 'misalignment' with the tax that would be legally due if tax laws were different: based on formulary apportionment.
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This measure creates apparent massive "illicit financial flows" out of ordinary tax compliance.https://www.cgdev.org/blog/proposed-sdg-indicator-illicit-financial-flows-risks-conflating-ordinary-business-dirty-money …
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He also fails to mention that most of what is included in *current* headlines on IFFs (and presented as being 'evasion by multinationals') is based on adding up gaps and mismatches in trade data which don't seem to be a good indicator of anything actually going on in tax.
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This researcher stands by her conclusion, and asks that next time if you going to try to take on someone's arguments in a national newspaper at least do them them the courtesy of saying their name.pic.twitter.com/ctcHlF9Dkm
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If one accepts that "the questions of legality and illegality, can't be separated from each other, whether definitionally, conceptually, or practically", one must choose between ''false positives' or 'false negatives'.
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And the article says little about what everyone would accept as criminal - criminal activities, corrupt practices, etc. This may lead to the elision of IFF and Avoidance. But IFFs are not all lost Govt revenues, so this important difference can't be used to yoke them together.pic.twitter.com/shFEvG2qYN
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