That’s not bad, but I prefer to compare tax avoidance, which is hard to define, with tax compliance which I find easier to define. Tax compliance is seeking to pay the right amount of tax (but no more) in the right place at the right time where right means that the economic substance of the transactions undertaken coincides with the place and form in which they are reported for taxation purposes.
In that case tax avoidance happens whenever someone chooses a course of action which results in the wrong amount of tax being paid, in the wrong place and at the wrong time.
Arcadia, the company, paid full corporation tax on its profits. Sir Philip Green paid full income tax on his salary. Lady Green is a foreign citizen living in foreign. We do not tax the incomes of foreigns living in foreign. For the economic substance of the transaction is the personal income of a foreign in foreign.
The Greens did not indulge in any tax avoidance therefore says Murphy.