Tax, transparency and development finance: a short tax-plainer for non-tax experts (like me) http://www.cgdev.org/publication/international-tax-transparency-and-finance-development-short-guide-perplexed …
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@MForstater if the planning gives rise to a TP adjustment, why is the filing position not on the curve, past the point of down-turn?
@_DavidQuentin - if the TP position might give rise to an adjustment by either jurisdiction then there is no way of getting off the curve!
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@MForstater yes, if tax planning gives rise to TP risk in two jurisdictions, then the logic applies (independently) to both filing positions -
@_DavidQuentin that seems to make all transfer pricing where there is any uncertainty about arms length price at all = “avoidance”
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