This has sparked widespread debate and the comments and blog entries have been rolling in thick and fast. Needless to say, opinion is very much divided.

Much of the analysis and commentary has been overly simplistic. Taxpayers are permitted to organise their tax affairs as they see fit, provided tax laws of a particular country are deliberately not contravened (tax avoidance as opposed to tax evasion). Any up-to-date transfer pricing professional knows that you cannot simply send valuable assets to a tax haven and watch the tax free profits pile up. It may be fair to say that this type of activity was common 15 years to 20 years ago, however, with transfer pricing enforcement being increased heavily over the past 10 years, particularly in OECD countries, tax planning now needs to be rigorously supported by legitimate business change. Senior people have to move. Decision making and risk taking functions have to move. Tax and transfer pricing planning cannot involve purely paper transactions.