Peter, #2027
Start? Work is ongoing...
http://www.hmrc.gov.uk/taxtreaties/news/programme-2012-2013.htm
If things were as complex as you suggest how can corporate tax liabilities be sorted by a postprandial handshake?
It is often asserted that the most complex of problems is like unto the knot of Gordius*, as you know. He was, in addition, the father of Midas, a most ill-starred line.
"Where there is a will there is a way." I say.
*
https://en.wikipedia.org/wiki/Gordias