[Acinyx]

Its pretty much pointless though, if you can't move all your revenue to an ip holding company, you just have to make it slightly more realistic.

In case of Starbucks: they move a ton of their profit to a coffee bean exporter from Switzerland which they own themselves. And how should a government say how expensive those beans can be?

Any company can outsource part of their revenue to a subsidiary in a different country like that and it would be extremely hard to encode in law when they wouldn't be allowed to do this "because of taxation". Uber could for example move their cloud management costs to some company in a low tax country, or maybe have their developers outsourced to some low tax country. How would you decide that is "valid" outsourcing vs "tax cheating" outsourcing?

[varispeed]

I think for companies that big, they should be required to launch a tender just like public sector e.g. for a supply of beans. This means their own beans company would be excluded because of conflict of interest. It won't stop them from delivering beans to other companies though, but it will make a tax fiddle much more difficult.