How can this loophole get fixed? My (admittedly minimal) understanding is that these companies don&#x27;t have to pay taxes on the money until they repatriate it. From the perspective of countries like the US or UK, Apple earns very little in &quot;profits&quot; because they have expenses in licensing fees between their own companies that effectively pushes the profit to countries with very low corporate tax rates.<p>This all sounds sinister and it certainly is clever. But I don&#x27;t see an easy way to fix it. I don&#x27;t think a tax system where countries can tax profit that never enters its borders is viable. How would the UK feel if the Cayman Islands levied a tax on profit earned by UK companies?