But they should be able to pay something to sister or parent company because they actually use the software developed there. The question is how much. Probably not all of the profits. I guess it's really hard to determine and define strict and fair rules in this area.
It is rather likely that the intellectual property for the google or Starbucks brand or the work that led to Pfizer patents etc were not developed in Bermuda, Bahamas or Panama. Itβs hard to exactly apportion where but rather easy to point out that near-zero IP work was done where it was declared to be taxable.
If we were talking about something that had a non-zero marginal cost such as tangible goods or services, I would tend to agree. The problem with (or benefit of, depending on your perspective I guess) IP is that apart from a fixed upfront investment (which granted can be substantial), it costs nothing to "produce" or transfer. Allowing a company to in effect pay licenses to itself, is therefore IMHO nothing but an invitation to the company to choose where it wants to get taxed.
I wonder if those sales could be force to an open market. A bit like anti trust laws.
I'm sure they would pay a lot more for their trademarks if other companies could otherwise snitch it for like a year.
Or why not having to accept or at the least pay taxes on the best offer you get, when you want to sell to some IP and later lease it from some other company?
Yes, that seems unrealistic. It might at least be possible to use this in e.g. the court of law to test for abuse.
