If we were talking about something that had a non-zero marginal cost such as tangible goods or services, I would tend to agree. The problem with (or benefit of,

If we were talking about something that had a non-zero marginal cost such as tangible goods or services, I would tend to agree. The problem with (or benefit of, depending on your perspective I guess) IP is that apart from a fixed upfront investment (which granted can be substantial), it costs nothing to "produce" or transfer. Allowing a company to in effect pay licenses to itself, is therefore IMHO nothing but an invitation to the company to choose where it wants to get taxed.