So the issue is more around transfer pricing, which wasn't really a thing until relatively recently. This has a really, really large impact on services, particularly computer enabled services, whereas in a world where most GDP comes from goods it's not really as big a deal (as you can tax the value-add from a factory much easier than you can from a software sales deal).
Unfortunately, the big corporations put a lot of money into finding ways around whatever law you pass, and the EU are not united on this stuff, at all, at all.