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MForstater's profile
Maya Forstater
Maya Forstater
Maya Forstater
@MForstater

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Maya Forstater

@MForstater

Business and sustainable development. Accountability. Tax. Feminist test case. Media: Tom Gardner at Slater & Gordon 0207 657 1690 press@slatergordon.co.uk

https://medium.com/@MForstater
hiyamaya.net
Joined September 2008

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    1. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
      • Report Tweet
      Replying to @MForstater

      @MForstater Amazon a clear example: operating UK service co & transacting from LuxCo introduces UK permanent establishment tax risk factor

      2 replies 0 retweets 0 likes
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    3. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
      • Report Tweet
      Replying to @fcablog

      @fcablog conclusion clear even ex ante: Amazon's advisers will definitely have considered the introduction of PE risk; negligent if not

      4 replies 0 retweets 0 likes
    4. Maya Forstater‏ @MForstater 14 Aug 2014
      • Report Tweet
      Replying to @_ClairQuentin

      @_DavidQuentin @fcablog - presumably if it ran each country biz as a PE there wld be transfer pricing risk - Is it clear that is less risk?

      2 replies 1 retweet 0 likes
    5. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
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      Replying to @MForstater

      @MForstater absent tax structuring it would prob operate its UK trade through a UK subsidiary but, in either case, yes less exchequer risk

      1 reply 0 retweets 0 likes
    6. Maya Forstater‏ @MForstater 14 Aug 2014
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      Replying to @_ClairQuentin

      @_DavidQuentin Why less? Is it obvious that all the t. prices 4 intl aspects of the biz (e.g. core tech, contracts) wld result in less risk?

      1 reply 0 retweets 1 like
    7. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
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      Replying to @MForstater

      @MForstater TP risk between two taxing jurisdictions e.g. UK/US is less than risk of trading profits going untaxed altogether

      1 reply 0 retweets 0 likes
    8. Maya Forstater‏ @MForstater 14 Aug 2014
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      Replying to @_ClairQuentin

      @_DavidQuentin I was thinking more that co. had already decided to have an EU base - then Q is how to structure relationships with it?

      1 reply 0 retweets 0 likes
    9. Maya Forstater‏ @MForstater 14 Aug 2014
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      Replying to @MForstater

      @_DavidQuentin PE risk is introduced at the point where the co. decides to operate from one EU HQ, not when it decides to locate it in lux

      1 reply 0 retweets 0 likes
    10. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
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      Replying to @MForstater

      @MForstater PE risk is introduced by structuring LuxCo as transacting entity for UK trade notwithstanding UKCo & UK operational footprint

      1 reply 0 retweets 0 likes
      Maya Forstater‏ @MForstater 14 Aug 2014
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      Replying to @_ClairQuentin

      @_DavidQuentin Right & for all other EU operations too. So moral turning point on graph = setting up single transacting entity for EU trade?

      5:03 AM - 14 Aug 2014
      2 replies 0 retweets 0 likes
        1. New conversation
        1. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
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          Replying to @MForstater

          @MForstater not quite - if they had not chosen a tax haven, there may not have been an aggregate increase in exchequer risk across jursdctns

          3 replies 0 retweets 0 likes
        2. Maya Forstater‏ @MForstater 14 Aug 2014
          • Report Tweet
          Replying to @_ClairQuentin

          @_DavidQuentin But if the risk in question is PE risk, this relates to the footprint operation not the choice of EU HQ?

          1 reply 0 retweets 0 likes
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        1. Heather Self‏ @hselftax 14 Aug 2014
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          Replying to @MForstater

          @MForstater @_DavidQuentin and I think VAT (Lux 3% on e books from memory) may be more important than CT in the structure?

          1 reply 0 retweets 0 likes
        2. Lastchristmas My Reflection‏ @_ClairQuentin 14 Aug 2014
          • Report Tweet
          Replying to @hselftax

          @hselftax possibly; would LOVE to have all the data and do a proper case study - got to zoom off now; thanks @MForstater for the engagement!

          1 reply 0 retweets 0 likes
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