Corporation tax has three purposes. One is to protect the income tax base from attack. The second is to tax capital, which by and large it does, making it a rare tax as a result. And third, it is a tax that should be used to apportion taxable benefits to those locations where value is added in the global supply chains that benefit us all.
Corporation tax isn’t – solely at least – incident upon capital, that’s the very problem with it.
But OK, suppose it is. Thus the tax will be incident upon where the capital is, and so it should be, not upon where the value add is. For it’s the capital adding the value, that’s why the return is to the capital.