This sort of thing is very easily gamed using transfer pricing. There's a worldwide effort to see whether it's possible to tax using some combination of where p

This sort of thing is very easily gamed using transfer pricing. There's a worldwide effort to see whether it's possible to tax using some combination of where profits are made, where the workforce is, etc. (OECD BEPS) but you can't "just" introduce a new bit of tax law and hope that it will survive the scrutiny thousands of tax lawyers eager to get their clients to pay as little as possible.