@_DavidQuentin thanks. Interesting model. Works for add on tax avoidance measures but I don’t think really helps w understanding on …
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Replying to @MForstater
@_DavidQuentin - international issues in the news. Google’s structure, transfer pricing etc… These issues don’t travel your pathway.
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Replying to @MForstater
@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?1 reply 0 retweets 0 likes -
Replying to @_ClairQuentin
@_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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Replying to @MForstater
@MForstater yes, if tax planning gives rise to TP risk in two jurisdictions, then the logic applies (independently) to both filing positions2 replies 0 retweets 0 likes -
Replying to @_ClairQuentin
@_DavidQuentin how do differentiate between “if doing biz internationally gives rise to TP risk” (seems unavoidable) and avoidance?
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Replying to @MForstater
@MForstater you accept the concept of tax planning in your own piece; do you not accept that it has a subcategory which engages TP risk?2 replies 0 retweets 0 likes -
Replying to @_ClairQuentin
@_DavidQuentin Q (genuine Q) where on ye pathway do u put G’s decision to make sales centrally? Or is it outside of model as ‘not planning’?
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Replying to @MForstater
@MForstater curious question; wholly uncontroversial that google's structuring is outcome of tax planning; why do you think I would say not?2 replies 0 retweets 0 likes -
Replying to @_ClairQuentin
@MForstater in any event, unless it falls into yr "abuse" catgry, G's structuring falls into the gap in your taxonomy that I have identified1 reply 0 retweets 0 likes
@_DavidQuentin I don't think uncertainty is the same as 'avoidance'
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