The American owner of Cadbury paid no corporation tax on its main UK business last year, despite making a profit of £177 million.
Mondelez UK legally avoided the tax bill thanks to a £42 million non-cash accounting gain from the sales of its coffee business, which was exempt from tax, and because it could offset other tax liabilities against interest payments.
The Sage of Ely tells us that avoidance is only avoidance if a provision of the law is used in a manner which no reasonable law maker would note or intend.
G. Brown specifically changed the law so that selling off a subsidiary did not attract tax upon the profits of having done so (SSE). On the grounds that he wanted to stop people claiming a credit on selling at a loss. Using the law as it was specifically changed to make you do so is not avoidance.
Interest on borrowing is a cost of doing business. Deducting it is not avoidance, it’s the law.
It ain’t avoidance, is it?