I simply believe that we need to move beyond 19th‑century thinking when it comes to tax policies and recognize multinationals as a single entity. Often, depending on what we are talking about, a multinational does not exist in law. What exists is a myriad of entities that are independent of each other and can trade with each other, borrow from each other, even sue each other and go completely mad. The board of directors co-administers all these structures, which are independent of each other and depend on the country where they are registered.
Now, if we wanted to enter the 21st century with a taxation system in step with the times, we could simply devise a method of calculation based on capital, number of employees and turnover, and then tax a multinational company directly on its estimated share of income in our country. In proportion to its presence in our country, it would owe our tax authority a certain percentage of its consolidated balance sheet, meaning of all its entities combined, regardless of whether the funds are in Hong Kong, Bermuda or Luxembourg.
This method presupposes a politically driven intent, coupled with a technical approach that specialists are well equipped to articulate.