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The loophole is setting up a multi-national structure to implement the base erosion and profit-shifting strategies discussed here:

https://www.oecd.org/tax/aggressive/beps-2015-final-reports....

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How is that a "loophole." Multi-national structures seem like a necessary facet of the tax code. And the listed strategies don't seem to take advantage of obscure provisions, but basic mechanics of the tax system: deduction of costs from gross revenues, etc.

Take a closer look at the sections on hybrid entities, treaty shopping, and transfer pricing. There are loopholes wide enough to let tanker ships pass.

"loophole" is a word for "a completely legal tax maneuver I don't like"

Worse, it's often a work for "a completely legal tax provision I don't understand."

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