At the core of many of these tax avoidance schemes is wholly owned subsidiaries making intra-group loans that are treated differently in different tax jurisdict

At the core of many of these tax avoidance schemes is wholly owned subsidiaries making intra-group loans that are treated differently in different tax jurisdictions. Imagne there is subsidiary X & Y in jurisdiction. In jurisdiction A the parent company declares those two subsidiaries should be considered a single entity, in jurisdiction C the parent company declares they should be considered separate. This allows intra-group loans between those two subsidiaries (and other subsidiaries outside jurisdiction C) to appear and disappear from the accounting as necessary for the purpose of tax avaoidance. Whilst the declared company structures are perfectly legal in jurisdiction A and C the fact that the parent company has declared different corporate structure for the same entities is deeply suspicious as an activity.