[johntb86]

Does it actually go to the US corporation, or to some European subsidiary?

[Nemo_bis]

For hyperscalers, to some EU subsidiary first. Then it depends on the transfer pricing applied. https://en.wikipedia.org/wiki/Transfer_pricing

You can tax the "intellectual property" payments that the subsidiaries make to the USA parent, or you can pick some other criterion. Or you can just create a new sales tax for any one part of the transactions you want. It's tricky but it can be done.