[nodamage]

You could certainly make that argument but with a multinational company with sales in every country it's not exactly obvious where the money is "made":

Scenario A: Apple (USA) pays $200 for an assembled iPhone from their Chinese manufacturer. Then they turn around and sell the phone to Apple (Europe) for $1000. Apple (Europe) then sells the phone to a customer for $1000. Apple (USA) records a profit of $800, Apple (Europe) records a profit of $0.

Scenarion B: Apple (USA) pays $200 for an assembled iPhone from their Chinese manufacturer. Then they turn around and sell the phone to Apple (Europe) for $200. Apple (Europe) then sells the phone to a customer for $1000. Apple (USA) records a profit of $0, Apple (Europe) records a profit of $800.

In scenario A the money is "made" in the USA. In scenario B the money is "made" in Europe. Apple argues that since they are paying taxes on that money in the USA, they shouldn't have to double-pay taxes to Europe as well. Europe disagrees because they want a slice of those taxes.

(Note that no complex IP transfer schemes are involved here, it's solely a question of which entity records the difference in the retail price of the phone vs the cost of goods sold. Also note that in either case, sales tax/VAT is paid to the appropriate country.)

[ThrustVectoring]

It gets even more complex and game-able when you consider how easy it is to shift deductible expenses to different locations. Suppose you fix things and force Apple(USA) to sell iPhones to Apple(Europe) for $600. What's to stop Apple from moving $400/unit of debt payments to their European subsidiary?