@georgenturner your example & S&P link is on third party debt. BEPS Action 4 / EU antiavoidance fixed ratio targets intracompany debt, no? 
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Replying to @MForstater @TaxJusticeNet
The fixed ratio in the BEPS action is total debt. Both intra-company and external.
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Replying to @georgenturner @TaxJusticeNet
Your dodgyco example & S&P leverage ratios etc on external debt. What light does that shed on Qs on use of intracompany debt?
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Replying to @MForstater @TaxJusticeNet
It is answering one question, does the BEPS action deal with this. It is saying that the cap is set so high that the action is meaningless.
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Replying to @georgenturner @TaxJusticeNet
The article leads with "MNCs can set up finance companies in tax havens to loan money to their operating companies around the world"
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I don't think the examples and data on external debt apply to the Q of BEPS effectiveness in relation to these internal debt issues?
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Replying to @georgenturner @TaxJusticeNet
How does yr ‘Dodgyco’ case & S&P data (re:external loans) relate to Q of BEPS4 effectiveness at stopping profit shifting via internal loans?
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Replying to @MForstater @TaxJusticeNet
It doesn't only relate to internal loans, there are avoidance techniques that use external debt too.
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Replying to @georgenturner
George i feel like we are going round in circles. Article says "MNCs can set up Fincos in tax havens to loan money to their Opcos"...
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& asks what impact BEPS will have on this. A good Q. I don't know the A, but its got to be based on that scenario, not an external debt one
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