Maya Forstater

No my point is most companies domestic & international, exporting & selling locally would by this definition be using 'compelled labour', so by the logic should adjust profits for tax of all firms by e.g. 50c per labour hour.

I get that it reads to you as a policy proposal and you’re skeptical. But the question driving this analysis is not policy or politics. It is whether value creation is a useful legal principle for allocating MNC profits and if so, how the principle may be interpreted.

That said I don’t disagree at all that politics and optics can easily get in the way of a paradigm shift.

Agree but Maya is correctly pointing out that underpaid labour in a market affects all prices not just related parties. Paper discusses this, suggests price adj outside of transfer pricing could be done; exploring interp of which legal rules is just a different paper.

Accepted. I thought I was supporting her approach by drawing attention to fact that UK rules involving ALP operate domestically, not just across countries. In other words, why limit the methodology just to MNCs?

To not apply presumably assumes that tax is fully paid domestically by all firms, incl those who benefit from misalignment, which may or may not be entirely true...