>Local subsidiaries are not usually resellers, and even if they were, the parent company can set an arbitrary price

The main reason why subsidiaries are set up is to enter a market and sell stuff. The main reason tax is discussed is because sales/revenue/profit is generated in one place.

And they do set up arbitrary prices within the limits of anti-dumping laws. But then again, someone somewhere will tax something.

>no direct revenues, just a big cash transfer to fund the costs from the parent company

In Apple (and many others' case), the local subsidiary has revenue. They actually bill consumers and collect payments.