Can be read in all its glory here. And he is of course still making the same basic error he’s been making for months now.
He defines things that are specifically meant and intended in law as not being tax avoidance. Of course they’re not sez ‘ee.
He then defines what Amazon and Starbucks are doing as tax avoidance.
But what Amazon does is indeed laid out in law. In the double taxation treaty: the use of warehouses and logistics chains does not lead to the creation of a permanent establishment. Therefore, although they are undoubtedly not paying tax as a result of the way that they have organised themselves this cannot be tax avoidance. For in Murphy’s definition of avoidance is the insistence that it is only the unanticipated or unmeant use of the law which can lead to such. And, of course, if the law says that warehouses don’t create a permenent establishment and a company uses warehouses but does not create a permanent establishment then this is the pure and simple use of the law exactly as it was intended.
Similarly with Starbucks over say royalties: the law (this time EU law) states that it is actually illegal for the UK to attempt to tax such royalties going to another EU country. Given that we really cannot conclude that sending royalties to another EU country is tax avoidance now, can we?
He’s simply blind to the fact that his own definition of tax avoidance means that a lot of what he’s complaining about is not tax avoidance.