?He tells us to read this paper.
In the commercial world the structuring of transactions and the drafting of
transaction documents is indeterminate while the parties to a transaction and
their advisers develop a consensus about how they want to proceed. In all
but the simplest transactions tax will be a factor affecting this process, and so
the eventual transaction (even if it is perfectly innocent of any suggestion of
tax abuse) will in such cases constitute an implementation of tax advice. That
tax advice may be thought of as having led the transaction on a journey where
the starting point is the form the transaction would have taken absent the tax
advice and the end point is the actual transaction as implemented. That
journey is treated in this paper as taking place through a two-dimensional
Ritchie’s the one who has told us that even asking for a tax opinion means that you’re trying to avoid tax. And yet here this paper, one he approves of, is telling us that everyone always asks for a tax opinion for every transaction and deal.