No, the problem is that the price of something is hard to estimate with tech. Apple, like everyone else, make use of transfer pricing tricks. They don't book pr

No, the problem is that the price of something is hard to estimate with tech. Apple, like everyone else, make use of transfer pricing tricks. They don't book profit in one country because the subsidiary there had to pay license fee to use the apple brand. The prices for that are obviously carefully chosen to minimise tax. But for a tax authority to dispute that and come up with a better value of the right to use the Apple brand is close to impossible. With manufactured products you have an idea what a product or brand is worth. But for the iPhone it's not clear what amount of the price accrues to the Apple brand.