Starbucks develops a "new brew". They fly the best coffee connoisseurs to a Liberian-flagged, Korean-built ship sailing from Saipan to Nauru, and develop a new formula there with equal parts Arabic beans and Robusta beans. They sell this new product worldwide, with marketing from a PR team domiciled in Malta, but operating in the Netherlands.
Where was the value created?
However, at the same time, they claim that the entity that runs the DLC purchase system is in Malta, where Blizzard has no employees, but uses an outside legal and accounting firm.
They claim all the value is in Malta.
I tend to disagree.
We should send tax cases to juries for decisions.
See RamBam episodes (in Dutch, but contain some English too):
> S04E11 Nederland Belastingparadijs broadcasted 29 Apr 2015
> S05E05 Russische bedrijven in Nederland broadcasted 17 Feb 2016
[1] https://nl.wikipedia.org/wiki/Rambam_(televisieprogramma)