I think the problem is that it&#x27;s really hard to pin down, in a legally operational way, which country &quot;really&quot; produced the good, when intelligent people are trying to tax-optimize it all.<p>Let&#x27;s say you concoct a scheme (pretty sure this is typical) where you have the artwork for a movie actually done in the UK, but on paper, you write it up like your selling the British workers&#x27; output to Luxembourg, then having the latter work on it, then buying it back into the UK at a huge markup.<p>Certainly, to an expert, it will be obvious that it&#x27;s a sham to say any art was produced in Luxembourg.  But this would have to be a distinction that can be seen by a tax accountant.  All they see is, &quot;Lux bought IP, UK bought their IP, seems legit&quot;.<p>Edit: rewrite for clarity