If only tax-evasion was so easily solved. The are not shy of restructuring completely just to fit into any gap that law created. On paper "BigBadCorpo US" and "BigBadCorpo Irealand" could be two completely separate entities, with BBCI turning zero to no profits becouse it license brand from BBCUS.
You would think that Worner Bross is a movie making company. It's not. On paper it's a company that lend very overprices movie equipment. To shell companies created solely for the purpose of creating one movie...
Taxes are hard and people who employ literal armies of layers have the edge over slow law making.
Company A is in Poland. You regulate law in Poland. Company B is in USA. You don't regulate a law in USA.
You want to tax company A, based on company B report, that was created for 3rd party government?