[alkonaut]

The US->Ireland->EU thing is exactly what's going on now, and exactly what proposals like this are trying to address.

This kind of system will only work within a group of nations that agree that this is a good idea, such as the EU. Ireland and the Netherlands probably don't agree - but can hopefully be forced.

Obviously no countries in the EU have territorial taxation.

[ringtail]

The US->Ireland->EU thing is exactly what's going on now, and exactly what proposals like this are trying to address.

Thats why gave this example to show that it does not work as profit remains the same.

Lets assume there is no US Co. Ireland Co is parent company and its only doing business in EU. Then either Ireland [1] allows low tax rates to attract business in which case profit is low and thus UK/France share is low. Or Ireland is high-tax, then business move to another low-tax in EU.

This only work if there is single tax rate in EU. But if there is single tax rate, then why even go this complicated tax calculation route.

[1] Estonia (and in near future Latvia) does not tax untill profit distribution, reducing effective tax rate to 0%.

[Xixi]

In your example if Ireland Co makes 30% of its sales in France, then it would have to pay taxes on 30% of its profit to France (at French rate). That limits the reason to go to Ireland in the first place, which is why Ireland is largely against it. In fact it would encourage corporations to move their costs to countries with large customer base and high taxation rates to reduce the profits there, so it would favor the like of France, Germany or Italy.

The "trick", if I understand, is to only care where the final service/product is actually delivered. So in your example the idea would be to ignore France SAS, or rather I imagine to assume Ireland Co and France SAS are one and the same, and tax them "together".

At first glance it sounds very hard to setup (and it certainly is), but that's what is being attempted here. On the other hand it's not particularly complicated to know whom Google is selling ads to, and where iPhones are sold, so there must exist a solution to this problem...