The main issue I see with all these tax avoidance measures is they are all based on not realizing profits in the tax year they were earned (and realistically it

The main issue I see with all these tax avoidance measures is they are all based on not realizing profits in the tax year they were earned (and realistically it'll become tax evasion in spirit if not by legal definition when a future govt lowers taxes or offers amnesty). Obviously a short comment isn't going to have the rigor needed to solve such a complex problem or figure out appropriate exceptions. Having said that I honestly believe appropriate governance laws that recursively apply to subsidiary and owned companies would be a very effective (even if not perfect way) for a single country to start realizing tax on their multi-nationals before the much slower wheels of international agreements can grind the problem away. My poorly thought out solution is along the lines of: Any company owning shares in another must attempt to vote every year that that the subsidary (or just invested in company) company pays out a dividend proportional to net profit and 3rd party investment since the last such passing vote. Any subsidiary incorporated by this company must apply these rules and any investment in the company is taxed when the subsidiary incorporates or buys stock in another company. They must also attempt to vote that any company they have shares in follow these same rules. No temporary transfer of shares or proxy appointment should effect the outcome of these mandated votes. I'm sure there are issues with my implementation of this idea such as longer planning of a warchest for growth or perhaps intuitive structures such as a subsidiary that manages all international subsidiaries but it was more to highlight a particular structure than to be exhaustively tuned.