The change that is very obviously needed is that a company must be considered resident where the economic substance of its management is located. And yes, that can be determined. It’s where a majority of the board and their senior management team work day in day out.
OK. So, say, BP, board and management all work in London (just as an example). So, BP is UK resident.
OK. Clearly, it should be paying tax where it is resident. OK.
So, err, BP shouldn\’t be paying tax in Angola, should it? BP\’s management and board aren\’t in Angola, so the company isn\’t resident in Angloa so BP shouldn\’t be taxed in Angola.
Which leaves your country by country reporting crusade looking a little threadbare, doesn\’t it?