They just don't get it
Currently these 'diverted profits' are written down as Franchise costs or IP costs etc etc. Why on earth does HMRC* think that they can produce a piece of legislation which achieves what they think they want? They have never managed it before and the multi-nationals have a lot more reasons to side-step the laws than HMRC* have to write them.
Can't wait for the first company to report every single purchase and salary payment they make throughout the year as diverted profit and drown HMRC in paperwork.
*OK, yes I know that technically it is not HMRC that write the laws but...