How do they manage the "no tax implications"? If the Irish entity has a licence for the IP, and 70% of the value of their licence is transferred elsewhere, tha

How do they manage the "no tax implications"? If the Irish entity has a licence for the IP, and 70% of the value of their licence is transferred elsewhere, than how does this not realise that value to the Irish entity and not be taxable? I am obviously not learned in this area, but the sleight of hand to move such a huge amount of value from one entity to another seems to me to create a huge tax liability now that the value would be leaving the tax domain.