Maya Forstater

@_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

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

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

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

@_DavidQuentin On your graph certainty & tax not payable two independent axis. Moral turning point relates to certainty axis.

@MForstater no, relates to both - there is no vertical drop! (no real world tax advice would deliberately create tax risk without an upside)