It's a good point David. $ shares only one way to look at it.
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I terms of my question David, I think it would go under (2) tax avoidance/ BEPS, but as you say because its a single share it is small
$s in BVI assets.
I guess from a BVI PoV wld argue 'nothing to see here' -- the structure & tax rules that enable the profit shifting are mainly the interplay between Ireland & US. Whereas critics wld argue offshore is a system & here is an example of BVI being part of a big $ BEPS structure
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Agreed. BVI isn't usual in this structure. It tended to be Cayman (for US groups) or Isle of Man (for Irish ones).
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Presumably the company could have been anywhere outside the EEA? Tax not a material concern given low value of holding. So came down to price/ease?
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