OK, let me give you a simpler example. BMW is domiciled in Germany. It builds cars there. When it exports a car to the US, it has a US subsidiary company that employs people and helps to sell the car in the US. BMW doesn't sell the car to its subsidiary, it sells it to a dealer (a separate company domiciled in the US, think "Jacks awesome BMWs, Toledo"). The profits that the dealer makes when it sells the car are taxed in the US, because it is a US domiciled company. BMW will probably pay something like sales tax and in some countries there will be import tariffs to pay. But the profit that BMW makes on the sale of the exported car, the difference between the price the US dealer pays them and the cost of all the raw materials, labour, marketing etc, is realised in Germany, and that's where they pay corporation tax. Because, where the hell else could it happen??