Professor Jim Stewart:

It is quite likely, for example, that profits arise in jurisdictions where there is no corporation tax. I know of two cases in which the company is incorporated in Ireland but is tax resident in other jurisdictions and its profits were €22 billion. I think €40 billion would be an estimate of the profits for US companies incorporated in Ireland but located for tax purposes in another jurisdiction. That €40 billion is in the US data but is in not in the Irish data.