So, in net terms the system is probably not
even a drain—at least not a large one—on the tax revenues. Nevertheless, the design,
negotiation and lobbying of the 2009 reforms demonstrated several lessons that would
have been useful earlier on. First, giving a complete tax exemption was probably
unnecessary, since there are positive yet small rates that can be applied and yield some
revenues, if designed in a way that they net out from tax credits applicable in their home
country. Second, once one has a positive tax, even if the rate is low, one can provide
incentives as credits against that tax for companies to do things that government finds
desirable or that the market under-provides, like training or R&D