Maya Forstater

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

@_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?

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

@_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?

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

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

@_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

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