But everyone accepts that (there's this little thing called BEPS). FA, however, is presented as a panacea.
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Replying to @DanNeidle @alexcobham
Comparing ALP vs idealised FA is unhelpful and unpersuasive. Real question is status quo vs real world FA (messy, imperfect & partial).
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Replying to @DanNeidle
ALP (demonstrably failed; no aim of profit alignment w. real activity); vs UT (aim of alignment; not yet failed). No panacea, but open mind?
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Replying to @alexcobham @DanNeidle
Support open minds. But if aim of ALP (and say CFC) is not to prevent avoidance of tax where real activity occurs, what is the aim?
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Are w sure what 'real activity' is? (stuff/people that can drop on/step on yr foot?) So much of prosperity is not driven by more of thispic.twitter.com/Gjo2kv4Vrl
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Replying to @MForstater @iaincampbell07 and
& If e.g. 'selling stuff in a shop'= example of real activity why wld selling iphones in Apple shop create more local profit than selling...
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Replying to @MForstater @iaincampbell07 and
...iphones in an authorized reseller? Looks like same real activity so ALP logic makes sense (as a relatively simple concrete example)
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Replying to @MForstater @iaincampbell07 and
So rather than the value being in the Caymans it actually derives from the sales and splitting the IP royalty on sales would be better ALP.
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Replying to @Stoorrrt @MForstater and
But (main?) reason people buy is to access product/brand name. So value not with customers?
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Replying to @iaincampbell07 @Stoorrrt and
but product/brand name value is a mix of build quality and popularity among other consumers.
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Right, but my point is all this is same whether customer buys from Apple store (MNC) or premium reseller (SME), local real activity same?
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Replying to @MForstater @MaryCosg and
Quite. But FA taxes differently. Distortive eve more MNEs start arranging their affairs to take advantage.
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