Comment by dbdr

There's at least one possible point, which is where the income is taxed. If data is not considered valuable, the German branch of company X can send data to its Irish branch, and the profit realized in Ireland (with very low tax rate), while this value was generated in Germany but the German state gets no income. And if Ireland raises its tax rate, send it to another fiscal paradise.

Potentially, if data was accounted as valuable, the income would be accounted for where it is generated, each country gets its fair share, and tax avoidance gets harder.