First, what exactly are "UK profits" supposed to be? Say Apple has a net margin of 20 % on every iPhone sold. It's designed in California by Americans (most surely several non-native Americans among them), manufactured in China by probably lots of Chinese workers and immigrants, shipped and flown across the world by god knows whom, etc. It's not like it's designed in Brixton, manufactured in Manchester and sold in London only. Which country is supposed to retain the tax on profit on each iPhone sold? The point of sale-country is one alternative. Is it the most logical? Is it equitable and fair (whatever that means)?
Second, if your local legislator is just too stupid - or, more accurately, for a lot of reasons - unwilling to close tax loopholes, why on earth should a company be willing to waste shareholder's money by settling a claim (tax) that is not legally binding due to existing loopholes? There is a lot of hypocrisy involved in politicians blaming companies for using tax law loopholes - if they were at all serious about that, they would just write better laws. Sure, it's always playing catch-up with tax lawyers looking for "tax-efficient" structures, but most loopholes are well known among legislators, and they knowingly decide not to close them.
First, what exactly are "UK profits" supposed to be? Say Apple has a net margin of 20 % on every iPhone sold. It's designed in California by Americans (most surely several non-native Americans among them), manufactured in China by probably lots of Chinese workers and immigrants, shipped and flown across the world by god knows whom, etc. It's not like it's designed in Brixton, manufactured in Manchester and sold in London only. Which country is supposed to retain the tax on profit on each iPhone sold? The point of sale-country is one alternative. Is it the most logical? Is it equitable and fair (whatever that means)?
Second, if your local legislator is just too stupid - or, more accurately, for a lot of reasons - unwilling to close tax loopholes, why on earth should a company be willing to waste shareholder's money by settling a claim (tax) that is not legally binding due to existing loopholes? There is a lot of hypocrisy involved in politicians blaming companies for using tax law loopholes - if they were at all serious about that, they would just write better laws. Sure, it's always playing catch-up with tax lawyers looking for "tax-efficient" structures, but most loopholes are well known among legislators, and they knowingly decide not to close them.