Maya Forstater

... but v rare to use Panama as a holding company jurisdiction because of poor rule of law and corruption (shipping an exception).

clearly this is not relevant to your conclusions, and indeed adds to your correct conclusion that OFCs differ in important respects.

A more important niggle. You say (footnote 21) there has been pressure on tax evasion. You mean BEPS Action 6- this is avoidance not evasion

You then say this is ineffective - but foonote 30 refers to completely different efforts to crack down on evasion. Jury still out on BEPS.

I need to go through properly, and may have more fundamental points - but these were some points of detail that jumped out at me. Thank you!

Footnote 21 is just one example of pressure on tax avoidance (shouldn't say evasion, we missed that one), we could have added more.

But I think footnote 30 is wrong reference, as it relates to something unrelated to anti-treaty shopping/corporate avoidance measures.

By the way, your methodology presents an obvious test for BEPS. Re-run the exercise in (say) three years time. See what has changed.