Where is the dividing line between acceptable and unacceptable tax planning for corporates?

Swiss leaks, Luxembourg leaks, the Panama papers, BEPS and the EU Commission’s Anti-Tax Avoidance Package – where will all this get us? Despite the public furore over the tax affairs of multinationals, there is still no clear dividing line between acceptable and unacceptable tax planning arrangements for groups. This is because the OECD, the EU Commission, the CJEU, HMRC and other tax authorities employ a number of different doctrines that try to identify what tax avoidance means. All that is certain is that the boundaries are constantly shifting and may be defined differently by different players.