Of course it could be argued that the second company is also making the money in the first country where it’s IP, trademark etc. gets used and has to be taxed t

Of course it could be argued that the second company is also making the money in the first country where it’s IP, trademark etc. gets used and has to be taxed there. Tax authorities already try to control for arbitrary cross country bills that try to shift profits (at least in some jurisdictions). The downside is more bureaucracy and unproductive friction of course.