[nikcub]

The more complex offshore structures take a lot of expert human effort and other capital costs to setup. To make them worthwhile requires a certain level of revenue, so it is usually only suited to medium-to-large sized businesses.

Apple and the other large companies can afford to keep the profit offshore. They are still paying full rates of tax on the revenue and profits they need to keep their businesses running.

When Apple pays a dividend, they will do it by paying full US tax rates on the dividend. Thus these tax structures are biased towards big companies only because they can afford to defer payments.

That said, all the knowledge that you need to setup a similar structure for a small business is available online and has become a lot cheaper. If you are accepting credit card payments you can setup in an offshore nation with a business registration, a bank account and a merchant account for a few thousand dollars.