Maya Forstater

@_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?

@_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’?

@MForstater curious question; wholly uncontroversial that google's structuring is outcome of tax planning; why do you think I would say not?

@_DavidQuentin 'cos I can't figure out how G fits on yr pathway. e.g. At what point do you place the decision to locate sales centrally?

@MForstater the curve is not for individual business decisions, it is for filing positions adopted pursuant to tax planning