100%. All of these schemes depend on the existence of a jurisdiction with low (or non-existent) corporate taxes that they can shift profits to in order to avoid paying taxes in the actual jurisdictions in which they manufacture and sell. Doesn't matter whether at its core it's a transfer pricing scheme, an IP royalty scheme, or a thin capitalization scheme. You need a man (country) in the middle with low/no taxes where you will recognize the profit you don't want taxed.