Apple creates products in California, contracts Foxconn to manufacture them in China using Japanese and Korean components, sells them in Germany, and records revenue in Ireland. Where is the profit made and how is it taxed? This has always been a problem, but it has gotten worse in recent decades, exacerbated by the emergence of extremely large global technology companies and countries competing on lower corporate tax rates. Now, the OECD has reached a preliminary global agreement on a new set of rules covering profit allocation and establishing a global minimum tax rate of 15%.