Maya Forstater

@_DavidQuentin thanks. Interesting model. Works for add on tax avoidance measures but I don’t think really helps w understanding on …

@_DavidQuentin - international issues in the news. Google’s structure, transfer pricing etc… These issues don’t travel your pathway.

@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!

@MForstater yes, if tax planning gives rise to TP risk in two jurisdictions, then the logic applies (independently) to both filing positions

@_DavidQuentin how do differentiate between “if doing biz internationally gives rise to TP risk” (seems unavoidable) and avoidance?

@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?