Re: Wrong argument
"all that branding and IP may be generated in the UK, but the head office may be in the USA."
I'm confused, or you are.
If the IP is generated in the UK under contract to an offshore entity as a product of work (UK design agency, Caymans company buying a logo) then who owns the IP? It has to be the latter because they're the client.
If something owned elsewhere is sold to a company in another country then that country own the IP going forward, so international sales would never be possible.
"Fair" isn't a useful word, its an emotive one. Fair means different things to different people. Some people think its "fair" that we have an ever increasing percentage of tax due the higher amount of money you earn. Others think its "fair" that we have a flat tax so everyone pays the same percentage thereby not penalizing success. Still others think it's "fair" that everyone pay the same amount of tax in pounds earned because everyone then has the same stake in the efficiency and scale of services provided for taxes raised. "Fair" doesn't really mean anything I'm afraid.
I especially don't see why that IP can then be handed over to GMC Cayman who then can license it back to GMC UK.
You don't see it because you're getting hung up on an emotional aspect of the tax treatment, rather than looking at the international trade component of it. Rather than have potentially 100s of dispersed legal entities cross paying or licencing IP from each other, and trying to handle 100s of different legal and tax treatments for each different piece of IP and royalties from it, it's much simpler to stay within the law by moving all the IP to one location, and its commercial sense to make that location somewhere low tax for IP purposes.
(Much the same as the famous band with their own hedge fund in Holland that manage their IP and royalty payments).
There's no imperative either moral, economic, or legal that mandates a person or entity to structure their affairs such that the maximum amount of tax is due - common sense dictates they structure it so the minimum amount is due. I think it was Lord Justice Hand that made this point? Could be wrong.
If I give a second house to my son, I am charged CGT as if I sold it at market rate.
No you're not. You can gift him whatever you like completely free of tax provided you survive for 7 years after the gift is given.
So charge Corporation Tax to GMC UK as if it had sold this IP on the open market, so something like ten times the total global revenue earned from it
Any charges against the local entity will reduce its taxable profit because it will make less profit due to the accounting charge. That will make the situation what you;d perceive as worse, not better, as they'd pay less tax.