[throwawayzRUU6f]

I believe something like the following would create an uncheatable system, and therefore will obviously never be implemented:

Does a corporation want to sell their products and services in country X? Very well, they must agree to the following regulation. The country X reserves an option to, at any point in time, buy up any subsidiaries or parts of the corporation, for value based on generally accepted accounting principles (GAAP). For example, if the accounting profit of Microsoft Germany is $0 over the past decade, the country has an option to purchase Microsoft Germany for its fair GAAP price - $0. After doing this, the country also has an option to reverse the trades the subsidiary has done. So, if Microsoft Germany sold its IP to Microsoft Ireland for the total value of $100, the country X can buy it back for $100. Repeat with Microsoft US, Microsoft UK, etc. The shareholders will be left with their extremely valuable (according to GAAP) Microsoft Ireland and Microsoft Singapore.

Any sufficiently large country with sufficiently motivated government can pull this off. No revolutionary overhaul of the existing tax system is necessary. The regulation is clear and fair. But again, it's never gonna happen.